According to a Human Rights Watch report published on February 19, 2009, the LTTE had been preventing Tamil people civilians from fleeing out of rebel held area and using them as human shields against the Sri Lankan Army offensive.. The report outlines that according to the NGO's own findings, the human rights violations "include deliberate, indiscriminate, and disproportionate attacks on civilians, hostage taking, and use of human shields." This is concluded in the report's own recommendations to the LTTE, stating that the use of human shields as well as the placing of military targets near civilian populations being a war crime as per the International Humanitarian Law found in IHL. Sri Lankan government's Maxwell Paranagama Commission stated that the LTTE was principally responsible for the loss of civilian life during the final phase of the armed conflict through their action to use fleeing Tamil civilians as Human Shields clearly differing with the Darusman Report.