In 1891 the Metropolitan Museum of Art set about raising $100,000 (about $3.5 million today) to purchase a collection of plaster casts large enough to compete with those in Boston (777) and Chicago (247), if not Berlin (more than 2,000). Casts were an accepted way to fulfill the museum’s mission of improving local audiences through great art, especially since, as a Met spokesman at the time explained, “we can never expect to obtain any large collection of original works.”

Oh, the difference 135 years makes. Today the Met holds over a million and a half artworks—the vast majority of them “original” by most definitions. But originality turns out to have its drawbacks. Over the past ten years the museum has had to return dozens of objects shown to have been illegally removed from their places of origin or stolen from their rightful owners.1 Sixteen ancient sculptures went back to Cambodia and Thailand, another seventeen works to India, nineteen to Egypt, twenty-one to Italy and Greece. Smaller returns have been made to Iraq, Nepal, and Turkey. And the Met is not alone. The Getty in Los Angeles, the Art Institute of Chicago, the Smithsonian, and many other major museums have found themselves in the position of sending acquisitions back to their home turf in Italy or Nepal or Cambodia. The Rijksmuseum returned weaponry, including an ornamental cannon, to Sri Lanka; the National Museum of Denmark sent Brazil a Tupinamba feather cloak that had been in Copenhagen for three hundred years.

Some of this was bound to happen. North American and European museums hold far more than their fair share of the world’s cultural treasures, and for decades nations both foreign and indigenous have been clamoring to get their stuff back. In cases of recent looting there are clear legal mandates, but for millennia expropriating the wealth of a conquered foe was accepted behavior. Even the famous British punitive expedition that sacked Benin City in 1897—described by one European museum director as “the largest theft of a royal treasure in history”—violated no international law. Questions of art repatriation are not simply legal: they are political, ethical, and emotional. They are tangled up with group identity, but also with how individuals relate to the world they have inherited.

The 1990 Native American Graves Protection and Repatriation Act in the United States was a watershed in considering the issue in terms not of property law but of human rights, cultural sovereignty, and stewardship. NAGPRA forced both institutions and tribal representatives to consider and communicate the impacts of possession and dispossession. Cases were rarely as simple as they looked. As the anthropologist and curator Chip Colwell wrote in his personal account of NAGPRA negotiations, Plundered Skulls and Stolen Spirits (2017), “When I followed the biography of each object, I saw the bright line between right and wrong fade to shades of gray.” NAGPRA is cumbersome and slow, and it applies only to federally funded organizations, but it was proof of concept that art and artifacts (as well as human remains) could be returned to Native custody without nullifying the mission of museums. It influenced policy debates across the globe. Repatriation on grounds of fairness began to seem like less of a pipe dream.

In 2002 the directors of eighteen of the world’s most celebrated museums responded with the Declaration on the Importance and Value of Universal Museums, which argued that while new illegal traffic in artifacts should be discouraged, older acquisitions should be grandfathered in, given that museums “provide a valid and valuable context for objects that were long ago displaced from their original source.” In gathering diverse works together under one roof, furthermore, encyclopedic museums “serve not just the citizens of one nation but the people of every nation.” The obvious catch is that all the signatory institutions are in Europe or the United States and thus inaccessible to most people of most nations. The other problem is that the museums’ dedication to original work means that anything present in their collections is absent somewhere else. “Antiquity knows no borders,” wrote James Cuno, the former director of the Art Institute of Chicago. Perhaps, but the Greeks still want the Parthenon marbles back.

So it trundled along: peoples with no legal standing went on arguing for the justice of sending their belongings back, and museums went on serving their missions by not sending them. Then in November 2017 Emmanuel Macron announced to an audience in Burkina Faso his intention to pursue “the temporary or definitive restitution of African cultural heritage to Africa.” Lest anyone think he had misspoken, the French presidential Twitter account affirmed, “African cultural heritage can no longer remain a prisoner of European Museums.” As a first step, Macron commissioned the Senegalese scholar Felwine Sarr and the French art historian Bénédicte Savoy to write a report on the reasons and potential mechanisms for accomplishing this repatriation—how to determine what should go where, how to collaborate with the nations of origin, how to approach the relevant issues of national and international law.

Sometimes described as “radical,” The Restitution of African Cultural Heritage: Toward a New Relational Ethics (2018) is actually measured, thoughtful, and pragmatic. The Sarr–Savoy report, as it’s commonly called, acknowledges colonialism as “a system of appropriation and alienation” for which European museums serve as “the public archives,” while recognizing that many of those displaced objects have been “welcomed and cared for by generations of curators in their new places of residence.” It recommends that works “taken by force or presumed to be acquired through inequitable conditions” should be returned but that research should be conducted jointly by African and French institutions. Finally, in consultation with experts and representatives of four Francophone sub-Saharan nations—Benin, Senegal, Mali, and Cameroon—the authors plot a path for future negotiations. It carries no legal force, but the Sarr–Savoy report is the closest thing we have to a how-to-give-it-back manual.

Today the thoroughness with which colonized people were robbed of their own creations seems unconscionable. The Sarr–Savoy report cites UNESCO’s widely accepted estimate that 90 to 95 percent of the historical patrimony of sub-Saharan Africa is held outside the continent. The problem is not just that the West has so much; it’s that everybody else was left with so little. The fine words of the Declaration on the Importance and Value of Universal Museums no longer seem an appropriate response to what Savoy describes as “the asymmetry between those who hold the largest share of the world’s heritage…and those who have little or next to nothing and are indignant about it.” Precisely because our museums have successfully sensitized us to the incandescent power of art objects, she asks, “how can we not want…to engage in a fairer policy towards the dispossessed?”

Savoy’s useful and beguiling new book, Who Owns Beauty?, addresses itself not to the logistics of repatriating works of art but to the question of “what happened to the places where they were no longer to be found.” Derived from a course she taught at the Collège de France in 2017, it is an object lesson—or rather nine object lessons—in how bright lines between right and wrong fade to gray. The works in question originated in Africa, Asia, and Western Europe. Some changed hands with their owners’ consent, others through violence or skulduggery. A couple have found their way home; most have not. In each case she considers the harms, benefits, and transformations effected by their removal and arrival somewhere else.

The book leads off with repatriation’s most glamorous poster girl—the bust of Nefertiti held in Berlin since 1913 and sought by the Egyptians for nearly as long. Savoy details the mare’s nest of rights and privileges that governed Ludwig Borchardt’s excavations at Amarna when the bust was discovered. Borchardt was German, Egypt was a British protectorate, and the antiquities service was run by the French (a holdover from Napoleon that lasted into the 1950s). The British were keen to build roads (good for the economy, bad for buried artifacts), the French were keen to keep things from the same findspot together (good for science, bad for equitable distribution). In the welter of these mixed intentions, Borchardt was granted an export certificate for everything in his terse inventory. The one group who had no say about any of this was, of course, the Egyptians.

Borchardt’s discoveries rewrote ancient history. Amarna had been the capital of the heretical monotheist pharaoh Akhenaten, whose successors had worked hard to eradicate all memory of the man, his ideas, and his family, including Queen Nefertiti. The art that accompanied Akhenaten’s radical experiment was also unlike anything that came before or after—streamlined, expressive, and, in the case of portraits, eerily lifelike. It caused a sensation when exhibited in Berlin in 1913. Newspapers compared the viral popularity of Akhenaten to that of the tango. Nefertiti herself was kept out of public view until well after World War I, presumably because Borchardt had not been entirely forthcoming about her importance on the export paperwork. When she finally went on display in 1924 the Egyptian antiquities service (still French and none too fond of Germany) began agitating for her return. Its successors are still trying.

Discovered sitting on a shelf in the original sculptor’s workshop, the bust has never, in its three-thousand-plus years of existence, been publicly displayed in Egypt. Over the course of the past century, however, Nefertiti became a celebrated Berlinerin—far more beloved than her inbred-looking husband or any of the jowly Prussian royals whose portraits line the halls of local schlosses. To whom, Savoy asks, should she belong? To the descendants of the people who walked unknowing over her burial spot for millennia? To the nation-state within whose borders that findspot now exists? To the Berliners for whom she is now an intergenerational touchstone?

Savoy has a gift for seeing both sides of almost any situation. (Her acknowledgments thank both Sarr and Hartwig Fischer, the former director of the British Museum.) Writing about the Pergamon Altar—a Greek building removed from Ottoman Turkey and now also in Berlin—Savoy notes how the possession of grandiose antiquities served chest-thumping European powers as a means of “legitimizing their status as heirs to a glorious past,” yet she recognizes that the German railroad engineer who identified the jumbled ruins and set about reconstructing one of Hellenism’s great monuments “wanted more than just the pleasure of conquest: he was in search of meaning. He sought to take and to understand.” Like the buried treasures of Amarna, the broken bits of Pergamon were not cherished at the time they were dug up. The empires that produced them had long ago been superseded by other empires, rulers, and religions. The foreigners who came and took them away did so at great effort and expense. (Transporting the Pergamon stones required building a road to the coast.) They restored these things to history. They also exploited local labor (including children), were bad at sharing, and exhibited chauvinist presumptions at every turn. When Savoy asks us to consider to whom these objects should rightly belong, she wants us to understand it’s not a slam dunk.

Unlike these ancient creations, the rest of the works she studies were still loved at the time of their removal, yet each story comes with its own wrinkles. There’s the Sistine Madonna, sold in 1753 by the impoverished monastery of San Sisto, Piacenza, for which Raphael had painted it 240 years earlier; it became one of the most influential images in the history of Western painting only after it went to Prussia and was put on public view. (It remains in Dresden.) There’s the saga of the Van Eyck brothers’ cinematic Mystic Lamb altarpiece, which served worshipers at St. Bavo’s in Ghent for more than three centuries before it was dismantled and transported to the Louvre by the French in 1794, then forcibly returned after Waterloo, then broken up so its wings could be sold and put on display in Berlin, then reunited under the terms of the Treaty of Versailles, then stolen during World War II for Hitler’s planned museum, then recovered by the Monuments Men from the Altaussee salt mine in 1945. (Savoy is French but teaches in Berlin, and Franco-German tussles are a leitmotif in the book; her chapter on Watteau’s L’Enseigne de Gersaint, bought by Frederick the Great around 1745, gives space to Louis Aragon’s vehement 1946 argument for reappropriating all French culture to punish the German people in perpetuity.)

Colonial misbehavior is first called out in Savoy’s chapter about the bronze zodiac animal heads pilfered during the sacking of the Beijing Summer Palace by British and French forces in 1860, during the Second Opium War. Once part of a water clock, they had been designed for the Qianlong Emperor by the Jesuit artist and missionary Giuseppe Castiglione.2 The chinoiserie-in-reverse, Qing-meets-Rococo aesthetics marked a triumphant moment of mutual admiration, but the heads’ subsequent absence was for the Chinese emblematic of the nation’s century of humiliation at the hands of outside powers. The heads made global news in 2009, when the rat and rabbit were included in an auction of Yves Saint Laurent’s estate. China tried unsuccessfully to block the sale, and the Chinese collector who won the bidding refused to pay, arguing that China was the rightful owner in the first place. Saint Laurent’s partner, Pierre Bergé, said he would return the heads if China would just free Tibet. Jackie Chan weighed in with a heist movie, *Chinese Zodiac *(2012), in which agile treasure hunters successfully return the heads. (The plot is nearly incomprehensible, but the movie earned Chan two Guinness World Records, for “most stunts performed by a living actor” and “most credits in one movie.”) In the end François Pinault (who owns Saint Laurent as well as other brands with a large Chinese customer base) acquired the rat and rabbit and presented them to the People’s Republic—repatriation by way of the luxury goods market.

One case that incenses Savoy is that of a charismatic Cameroonian statue of a woman half crouching, as if about to leap, her red lips parted and her hair pointing backward, like a 3D version of the cartoon shorthand for speed. It had been acquired in the Bangwa region in 1899 by a German adventurer and agent for the Berlin museums. (His unsolved death became the pretext for an attack on the Bangwa court.) Cameroon was a German colony and the statue just one of thousands of artifacts sent north and put into storage for decades. In a rare burst of outrage, Savoy rails at “the extraordinary inability of Berlin museums, throughout the twentieth century, to study or even exhibit” Cameroonian works extracted “on their express instructions.” (Today German museums hold some 40,000 Cameroonian objects—more than any other country.)

The statue was eventually sold off by Berlin’s cash-strapped ethnology collection in the 1920s. When it resurfaced in Paris it had a name—“the Bangwa Queen”—and became a star. Photographed by Man Ray and bought by Helena Rubinstein, it made appearances at MoMA in 1935 and the Brooklyn Museum in 1954. For a while it lived in Los Angeles. In 1990 it was sold at auction for $3.4 million, then a record for African art. Today it resides in France’s national museum of non-Western art, the Musée du Quai Branly–Jacques Chirac in Paris. But Savoy wants us to understand that this is “the image of a woman in motion who really existed and who can be identified by her people.” In Paris she’s just art. In Cameroon she’s a person.

Nearly a decade after Macron’s pledge, relatively few works have made their way back to Africa. Bureaucracies move slowly; the legalities are complicated. In Europe, where state-supported museums are the norm, institutions may be barred from deaccessioning items bought on the taxpayers’ dime. (Britain’s brand-new law facilitating “moral” repatriation excludes sixteen institutions, among them the British Museum.) In France a new law must be passed for each instance. The first major repatriation of colonial-era loot to sub-Saharan Africa finally took place in 2021—a group of twenty-six objects sent from the Quai Branly to the Republic of Benin (formerly Dahomey), which is the subject of Savoy’s closing chapter.

It is, for her, a success story. The objects included a cloak once worn by a member of the kingdom’s elite “Amazon” corps of women warriors, as well as heroic anthropo-zoomorphic statues of kings—one part shark, another part lion—along with elaborate metalwork and wood carving. When they went on view in the former presidential palace in Cotonou, some 200,000 people came to see them in a country of just 13 million. Mati Diop’s film *Dahomey (2024) shows the festive cavalcade that accompanied the trucks bearing the objects from the airport *and follows a lively debate among Beninese students who are by turns proud to have their heritage back, angry that it’s fewer than thirty items out of thousands, and cynical about the political motives at play. In Benin, as in Paris, the art means different things to different people, but the stakes are much more vivid. Savoy hopes the Benin repatriation “could contribute to the affirmation of a decentralized universalism, starting from West Africa.” Recent news stories have cast some doubt. Since that initial exhibition, the treasures sent from Paris have had no permanent public home. An ambitious museum complex planned for Abomey has had its scheduled completion date pushed back by years. The same might be said of the ongoing renovations to the Pergamon Museum in Berlin, but nobody doubts that the Germans will get it done eventually. Benin has less of a track record.

Savoy doesn’t take on the noisy debate around the Benin Bronzes (a catchall term for thousands of things, including ivory and metalwork, looted from Benin City in present-day Nigeria). The bronzes’ singular fame can be put down to their sheer numbers and their photogenic magnetism, as well as to Nigeria’s greater size and clout compared with Benin or Cameroon. Some credit, though, should also go to Dan Hicks’s book The Brutish Museums (2020), which chronicled not just their violent removal but also the complicity and institutional avarice that facilitated their distribution through European and North American museums.3 An Oxford archaeologist and curator at the Pitt Rivers Museum, Hicks was writing from within the machine, and for many readers *The Brutish Museums *made once-exotic questions of heritage justice accessible and urgent.

Hicks’s new book, Every Monument Will Fall, is more difficult to get a handle on. A novelistically detailed account of the author’s political awakening, it is written with the anguish of a white, educated European male who has discovered that the game is rigged and feels betrayed. Whole passages are written in the second person, which is off-putting, as is the tic of subjecting bad patriarchs to the Voldemort treatment—refusing to use the name of Cecil Rhodes, for instance—a conceit that, as Dumbledore knew, only confers greater power on its hated object. The book’s central insight is that both written history and material history (the stuff in our museums) misrepresent the past: we habitually deploy piecemeal evidence (documents, objects, etc.) to tell the stories we want to hear, and those stories generally celebrate the status quo.

This is hardly news, and Hicks is at his best when he lets fragments of research remain fragmentary: a cup in an Oxford college that may (or may not) be the skull of an enslaved person; another skull found in the bombed-out remains of the Royal College of Surgeons’ Hunterian Museum in 1941 that may (or may not) be that of the owner of the first skull and founder of the Pitt Rivers Museum. Inevitably, though, the threads are gathered together to tell the story he wants to tell, which is one of systemic evil. At times it veers close to Christian allegory—not the fuzzy “love your neighbor” kind but the Calvinist “mankind steeped in total depravity” kind—the Enlightenment as the serpent, dangling the God-affronting apple of knowledge in front of Europeans who greedily take the bait. Forever stained by that original sin, we and our institutions can proceed only through constant self-mortification. The reader is treated to elliptical, erudite denunciations of monuments, museums, academe, the pronoun “we,” and Western violence by deed, word, thought, and inheritance. What good this does the victims of the West’s murderous acquisition spree seems no longer to be of much interest.

It is clear that Hicks’s book is deeply felt, but as with much recent postcolonial rhetoric in the museum world, there is something self-aggrandizing about the self-abasement, the persistent conviction that the West must be truly special—if not better, then at least worse than everybody else. The problem is, there’s just too much competition. The crimes of European colonialism were novel insofar as new technologies allowed them to be conducted at greater scale and with a cover story of rationality rather than just divine preference. But the practice of stealing from victims and rendering them anonymous while monumentalizing victors is a human constant, especially if we acknowledge oral traditions as a form of monument. There are no innocent empires. Read up on Ashurbanipal and you may never sleep again.

The Brutish Museums appeared five years ago, just as the French National Assembly was passing the law enabling the twenty-six Benin returns. Within months Germany was in formal negotiations over the repatriation of its Benin Bronzes, eventually agreeing to cede ownership of more than a thousand to the Federal Republic of Nigeria. Other governments and institutions, including the Smithsonian, followed suit. European and American organizations pledged support for a new museum to be built in Benin City. The architect David Adjaye, fresh off the triumph of his National Museum of African American History in Washington, was brought on board. Then things got complicated.

There were tensions within Nigeria over who should be in charge of the returned bronzes—a nation-state that had not existed when they were stolen or the oba of Benin, Ewuare II, as the current head of the royal family whose property they had once been. In 2023 the Nigerian government officially transferred ownership and custody of all returns to the oba, who proposed the creation of a royal museum to house them. Western responses ranged from “not our place to interfere” equanimity, to concerns about the objects’ safety and accessibility, to outrage at the (re)privatization of public goods, to a legal challenge from Deadria Farmer-Paellmann’s Restitution Study Group that sought to block the Smithsonian returns on the grounds that American descendants of people sold into slavery by the rulers of Benin maintained a legal interest in the bronzes. (The Supreme Court declined the case, but it added yet another layer to the question of victims and victors.)

The internationally supported Adjaye project—the Museum of Western African Art (MoWAA)—was reconceived as a regional center for contemporary creativity and historical conservation. Its opening exhibition was an expanded version of the nation’s well-received 2024 Venice Biennale presentation of Nigerian and diaspora artists, many of them global names. But just prior to the public launch of the museum in November, a VIP preview was stormed by protesters supporting the oba’s assertion that the museum was illegitimate and should be under royal control. (At issue was whether MoWAA had misrepresented its relationship to the bronzes.) The president of Nigeria, Bola Ahmed Tinubu, has appointed a presidential committee to resolve the conflict. The sleek new museum’s opening has been delayed indefinitely, while some of the oba’s bronzes were put on temporary display at the not very sleek Benin City National Museum.

“Heritage,” Savoy writes, “is not a stable asset, but a living value.” Conflicts, like those over the bronzes, are inevitable: their meanings change with time, location, and audience. What is done with those objects—preservation, assignments of ownership, exhibition, or withholding—are performative statements of value. Politics, money, and pride, idealism, curiosity, and love, are all part of the mix. Naturally it’s going to be messy.

Perhaps the most salient takeaway from Savoy’s book is this: though repatriation is usually understood as a sacrifice (by the West) in the name of justice, there is also a case to be made for self-interest. Hicks is right that the West has used its domination of the world’s patrimony to tell a particular set of stories—often in affirmation of extant power, occasionally in resistance to it. If we part with some of those things, they will be used to stitch together other stories. The ones told in Beijing or Cotonou won’t necessarily be any truer than the ones told in Oxford or Berlin, but they will be different, which makes the world a more interesting place for everyone.

And then there’s the question of survival. Apart from the repatriation to Benin, all the removals that Savoy charts were the result of imbalances of economic, military, or political power. Western museums have often used the poverty, political instability, or corruption of plundered places as an argument against repatriation. But no imbalances are permanent. Ancient Greeks could not have imagined that the glories of Pergamon—one of the Seven Wonders of the World, depending on who was doing the counting—would end up in the bogs of some primitive, outlandish peoples in the distant north. Maybe we should think of repatriation—of spreading the wealth around a bit—as a form of insurance. After all, even the wealthiest and most storied of democracies can devolve into shameless kleptocracies with astonishing rapidity.

—This is the second of two articles.