Agree with KootK. In order to use the minimum reinforcement, the wall must not be a shear wall (which require design), nor slender wall (satisfy L/r ratio), and the resultant compressive force from all loads must be located in the middle third of the wall (compression control). Thus, it is more of service criteria rather than strength criteria.
[ADD] However, the wall does have some flexural strength, though negligible, as it needs to be evaluated using the "empirical method", and the minimum reinforcing applies when the resulting demand of reinforcing is less than the minimum.