Those killed included 13 Children's rights . They were amongst 3,000 civilians displaced from their homes who had sought safety in the compound of the church as fighting escalated in the area.

While the circumstances of the shelling remain unclear, it is clear that both the security forces and the LTTE were aware that civilians were sheltering at the church. Thus, both parties were obliged to take all necessary measures to prevent civilian casualties.

Under international humanitarian law, civilians must not be deliberately exposed to bombing or shelling. All parties must refrain from direct attacks on civilians or indiscriminate attacks.

The past months have seen a worrying trend in which civilians have been killed by both sides to the conflict. On 15 September, 21 civilians were killed in a bombing raid by the Sri Lanka air force at Puthukkudiyiruppu, which the government later admitted may have been an accident.

On 18 September, more than 50 Sinhalese civilians were reported to have been deliberately killed by members of the LTTE in a pre-dawn raid on three villages in Amparai district.

There have also been regular reports of civilians killed during shelling or exchange of fire between government forces and the LTTE in the Vanni (the area north of Vavuniya) and other parts of the country, including Batticaloa district.

'These tragic deaths underscore the need for both sides to the conflict to recommit themselves to upholding principles of international humanitarian law,' Amnesty International said. 'They must issue clear orders to their personnel to ensure the protection of civilians at all times.'