Evidence Submitted to: The People’s Tribunal on Sri Lanka – Dublin, Ireland
14th, 15th January 2010
1. The SLA and Sri Lankan state agents, in a joint criminal enterprise with common criminal purpose and design and which operated under the military command responsibility of multiple persons, including but not limited to President Mahinda Rajapakse, Defense Secretary Gotabaya Rajapakse, former Lt. General Sarath Fonseka, Brigadier Rohana Bandara, Brigadier Satyapriya Liyanage, Brigadier Nishantha Wanniarachchi, Brigadier Shavendra Silva,
and Brigadier Jegath Dias, carried out through affirmative act or culpable omission, a disproportionate, indiscriminate, widespread and systematic pattern of direct or indirect attacks on areas in or nearby PTK hospital inside a neutralized government-designated Safe Zone between at least 01/09/2009 and 03/05/2009, which caused the deaths of at minimum 462 Tamil civilians, and which severely injured at minimum 867 Tamil civilians.
2. During times within which PTK hospital was functioning as a hospital, these attacks targeted Tamil combatants and Tamil non-combatants inside and outside PTK hospital without distinction.
3. It is reasonably inferable from the available and preponderant body of admissible evidence – including TAG satellite imagery, TAG eye witness testimony, WWW video footage, WWW land-based photography, human rights reports – that these attacks were committed by the joint
criminal enterprise in violation of customary IHL.
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