Human rights organizations accused Russian forces of engaging in indiscriminate and disproportionate use of force whenever encountering resistance , resulting in numerous civilian deaths ( for example , according to Human Rights Watch , Russian artillery and rocket attacks killed at least 267 civilians during the December 1995 separatist raid on Gudermes ) . The dominant Russian strategy was to use heavy artillery and air strikes throughout the campaign , leading some Western and Chechen sources to call the air strikes deliberate terror bombing on parts of Russia . Ironically , due to the fact that ethnic Chechens in Grozny were able to seek refuge among their respective '' teips '' in the surrounding villages of the countryside , a high proportion of initial civilian casualties were inflicted against ethnic Russians who were unable to procure viable escape routes . The villages , however , were also heavily targeted from the first weeks of the conflict ( Russian cluster bombs , for example , killed at least 55 civilians during the 3 January 1995 Shali cluster bomb attack )
1995 Shali cluster bomb attack
1995 Shali cluster bomb attack
First Chechen War