The church attack occurred in the western city of Eldoret, where some of the worst violence has occurred in the days since incumbent President Mwai Kibaki won a second term in an election that has been declared seriously flawed.
Police says most of the victims of the fire were from the Kikuyu tribe, who tended to back President Kibaki during the election - making them targets for attacks by supporters of opposition candidate Raila Odinga, whose followers are mostly ethnic Luo.
The attack and violence in recent days has left about 275 people dead and sparked fears of a wider ethnic conflict in Kenya as Luos press their demand for Kibaki to give up his seat. The city of Eldoret, where the church was set on fire, has seen intense clashes that killed hundreds of people in previous elections, but those flare-ups did not lead to widespread conflict elsewhere.
The violence in Eldoret came soon after the European Union issued a report saying it had serious doubts about the vote-counting process and the chairman of the electoral commission, Samuel Kivuitu.
At a press conference, EU mission chief Alexander Graf Lambsdorff said he thought the parliamentary elections were genuine, but not the vote for president.
"We continue to have doubts regarding the presidential elections," he said. "We see question marks and have to have doubts about this due to the lack of transparency. I would have to say that I include the chairman when I say that we have doubts about the results announced by the ECK [Election Commission of Kenya], simply because he is part of and in fact leader of the ECK, and if we doubt the results it would not be fair to exclude any of the ones responsible."
While Nairobi maintained an uneasy calm, Kenyans were waiting fearfully for Thursday, when Odinga has called for a million people to come into downtown Nairobi to declare him the people's president.
Odinga told reporters that he believed President Kibaki was part of the old way of Africa and must be removed.
"I am only pained by what is happening, and I will say that President Kibaki represents the old leadership, that old dictatorial leadership that is on its way out of Africa," he said. "So I will say that he is part of the endangered species of leadership that belongs to the museum."
Mr. Kibaki said all political parties should meet and call for calm, but Odinga has said he will not negotiate or meet with President Kibaki until the president cedes power to him.