"Preventing terrorist attacks often turns into exploded apartments, demolished houses and a handful of bodies," Rasul Kadiev, a prominent human rights lawyer in Dagestan, wrote in a comprehensive blog post on the policy last year.
Kadiev has been vocally opposed to the policy on not returning the bodies, calling it "immoral" and "barbaric."
What complicates Tsarnaev's case even more, the experts say, is that he was killed overseas and not in Russia or by Russian security forces. The difference could make the case a matter of international law that leaves even the most seasoned Russian lawyers in the field scratching their heads.
Still, there are cases where the bodies of militants have been allowed to be buried in the open.
One such case is that of William Plotnikov, a Russian immigrant to Canada who converted to Islam and traveled back to Dagestan to join a militant group. He was killed in a police raid in July near the small Dagestani village where he lived and was buried in a marked grave nearby.
Investigators, it should be noted, are looking into whether Tsarnaev had any contact with Plotnikov before or during a six month visit to Dagestan last year.
Experts, however, stress that such a case is the exception rather than the norm.
In the past, lawyer Kadiev said, some families were able to pay a bribe (which could exceed $16,000) in order to get their relative's body back. But a crackdown on that practice in recent years means it is now extremely rare, if not impossible.