BODY AND SOUL: FIDUCIARY DUTIES AND THE ART AGENT: THE APPEAL IN THE DE PURY LITIGATION: ACLBDD Holdings Ltd v. Staechelin & Others.
With those words Jacob L.J. in the case of Imageview Management Ltd v. Jack (2) reiterated the fiduciary duty of loyalty owed by agents to their principals. That was a case involving a footballer's agent. But the legal principles apply with equal force to agents operating in today's complex art market. With sales in the secondary market, the incentive to get involved when a work becomes available is a strong one, and the way to get involved, and earn a commission, is to know someone or know someone who knows someone. Sales of art works can sometimes involve layers of dealers between buyer and seller, with the principals on the two sides of the transaction sometimes not even knowing who is on the other side of the deal.
It is topical, therefore, that the appeal in ACLBDD Holdings Ltd v. Staechelin & Others in one of the most public disputes in recent years between principal and agent about the right to commission on the sale of an art work, has recently been decided by the Court of Appeal. At the heart of the dispute was a fundamental and bitterly fought disagreement between, on the one hand, art agents Simon de Pury and his wife Michaela de Pury, and the corporate vehicles through which they carried on their agency, and, on the other, Ruedi Staechelin and his fellow trustees concerning a commission of US$10M alleged to be due following the sale of Paul Gauguin's painting Nafeafaa ipoipo to the Qatari royal family for US$210M. In rejecting all of the grounds of appeal advanced by the trustees, the Court of Appeal upheld the decision of the trial judge in favour of Mr and Mrs de Pury, and agreed that there had not been any breach of fiduciary duty disentitling Mr and Mrs de Pury to their commission.
What was reportedly said by counsel acting for Mr Staechelin and the other trustees before the trial was that there had been "a clear breach of fiduciary duty and all commission had been forfeited if any right ever existed". This was a sound-bite that neatly captured the issues which the court had to decide. As highlighted in an article published in Art Antiquity and Law last year, (3) the case attracted attention not just for the eye-catching size of commission but also the remarkable fact that there was no written agreement recording the terms agreed as to commission. Since any agreement was reached orally--direct written evidence of the existence of an agreement being limited to five words in a note of a meeting: "Commission (Simon) $10m if $210M"--the most significant issue at trial was whether a sufficiently certain concluded agreement had ever been reached.
The trustees also contended that even if an agreement had been reached it was not a legally enforceable agreement since it had not been approved by all three trustees acting unanimously. They also argued that, even if there had been an agreement, Mr and Mrs de Pury had breached their fiduciary duty towards the trustees and, as a remedy for that breach, any commission should be forfeited. Essentially, on that issue, Mr Staechelin was fixated by the notion that Mr de Pury had told him a lie about whether an earlier higher offer had been made by Guy Bennett, the director of collections and acquisitions for the Qatari Museums and agent for the Qatari royal family.
There were as a result four issues at trial:
(1) contract formation: was there ever a legally enforceable contract to pay commission of US$10M;
(2) reasonable remuneration: if there was a legally enforceable contract to pay commission, but no agreement about the amount, what commission was payable;
(3) trustee decision-making: did it matter that there was no resolution by all three trustees to pay commission;
(4) forfeiture of commission: did Mr and Mrs de Pury owe a fiduciary duty, and, if so, had they broken it and should the Court declare any commission forfeit.
In terms of the underlying facts, and in order in particular to understand the arguments on appeal on issues (3) and (4), there were lengthy discussions conducted at meetings, by email and telephone calls over a period of two years. These facts are recited at length in the first instance judgment, but very briefly summarised, they can be divided into four phases:
* August 2012 to April 2013: During this period Mr Staechelin, Mr and Mrs de Pury and Mr Bennett had meetings at a restaurant at Zurich Airport and at Mr and Mrs de Pury's home in London. After some further discussions directly between Mr de Pury and Mr Bennett, Mr de Pury reported to Mr Staechelin that Mr Bennett had a made an offer of USS230M. As it transpired, Mr Bennett later said that he had never made a 'formal' offer and this became the major bone of contention for Mr Staechelin mentioned earlier. Mr Staechelin and Mr de Pury agreed that Mr de Pury should counter-propose a sale at USS260M as a result of which, if accepted, Mr de Pury would receive US$10M in commission. Mr de Pury made that offer by telephone. Apparently, Mr Bennett reacted angrily and said the deal was off. Discussions ended at that point.
* January 2014: During this period Mr and Mrs Staechelin and Mr and Mrs de Pury had a meeting in Rome, following which Mr de Pury emailed them to say he had had a further telephone discussion with Mr Bennett. This led to a second meeting between the four of them at the Staechelins' home in Basel. Mr Staechelin asked Mr de Pury to contact Mr Bennett. Payment of commission--either a flat rate of 5 per cent or a fixed fee of US$10M or some other figure once an eventual sale price was agreed--was also mentioned at that point.
* June 2014: During this phase Mr de Pury and Mr Bennett met in Basel and Mr Bennett said the offer was now US$210M. This was said to be for two reasons: (1) the market for Impressionist works had declined; (2) the former Emir had abdicated and the new Emir was less interested in such works. That offer was put to Mr Staechelin the following day who said he wanted time to think about it. At that point he telephoned one of the other trustees, an English solicitor, Martin Paisner. The third trustee, a US lawyer, Carlyn McCaffrey, was not consulted at this stage. This was first occasion on which Mr Paisner was made aware that a sale of the painting was a possibility. A meeting was set up between Mr Staechelin, Mr Paisner, Mr de Pury and Mr Bennett at Mr Paisner's offices. Mr Bennett said the offer of $210M was an all-or-nothing figure. At that, as the judgment later recorded, Mr Staechelin removed his tie featuring a reproduction of the painting and ceremoniously handed it to Mr Bennett signifying what was referred to in the judgment as a "mood of acceptance". This was the meeting in respect of which the five-word note mentioned above was made.
* July to September 2014: Notwithstanding what had taken place at the meeting, Mr Staechelin and Mr Paisner decided they should attempt one last time to get a better price. Mr Paisner telephoned Mr Bennett indicating that the trustees wished to proceed but only at the best price previously offered; i.e. US$260M. At this Mr Bennett apparently said that he wanted it to be clear that he had never offered US$260M. Mr Paisner reported this to Mr Staechelin who telephoned Mr Bennett saying that Mr de Pury had told him Mr Bennett had made an offer of that amount. But Mr Bennett said that was not true. Mr Staechelin's reaction to this was that Mr de Pury had told him a lie in order to get him committed to a sale. He asked for a written confirmation from Mr Bennett which Mr Bennett provided albeit in careful terms stating that he had never made a 'formal' offer. Mr Staechelin, Mr Paisner and Ms McCaffrey proceeded to sign a written resolution agreeing to sell the painting for $210M. The resolution said nothing about commission and Mr Staechelin and Mr Paisner did not discuss it with Ms McCaffrey.
This resulted in a concluded contract for the sale of the Gauguin on 10lh September 2014. This was followed a few days later by a blunt email message from Mr Paisner to Mr de Pury: "Let me make it absolutely clear immediately that my clients neither have, nor at any time had, any obligations to you whatsoever and that remains their position." The claim was issued a week later.
The trial was heard by Morgan J. over nine days in June and July 2017. His judgment was reported in greater depth in the article in Art Antiquity and Law. (4) In short the principal task of Morgan J. as the trial judge was to evaluate the evidence and make findings of fact. As appears from the judgment this was not entirely straightforward. Having heard oral evidence from Mr Staechelin and Mr and Mrs de Pury, Morgan J. recorded his reservations and set out how he proposed to resolve them:
I did not find the evidence of Mr de Pury, Mrs de Pury or Mr Staechelin to be wholly reliable ... I will treat much of the evidence given by [them], in so far as it is not supported by the documents, or which is not corroborated by another reliable witness, with caution. I am likely to accept evidence from a witness where the evidence is against his interests in this dispute. However, these techniques will not be enough on their own to resolve the conflicts in the evidence in this case, ... where I am faced with two conflicting accounts from witnesses, neither of whom is wholly reliable, I will have to assess the overall probability of one version as compared with the other.
The judge was particularly troubled by some evidence given by Mr de Pury: "I consider that Mr de Pury's evidence on this was point was deliberately misleading in an attempt to improve his case overall." He also found that Mrs de Pury's evidence in one respect "astonishing".
Applying this approach, Morgan J. found on the first issue that a sufficiently certain consensus was reached at the meeting in the third phase of negotiations to the effect that a commission of US$10M would be paid if the painting was sold for USS210M. He therefore did not need to decide the second issue (although he found that reasonable remuneration would have been 7.5M [pounds sterling]). As to the third issue he held that it did not matter that Ms McCaffrey had not been consulted about the payment of commission. Article X(C) of the trust instrument provided for majority decision-making and none of the trustees had declined to participate in the decision under Article X(A) such as to displace that provision. On the fourth issue, he rejected the trustees' argument--that Mr and Mrs de Pury were in breach of duty (1) by colluding with Mr Bennett not to tell the trustees that the statement that there had not been an offer of USS260M was false; and (2) by not telling the trustees that Mr Bennett's statement was false--on the facts. He held that it was significant that Mr Bennett had used the words that he had never made a formal offer, and that various factors explained why Mr de Pury did not say there had been an offer, not least that he thought that Mr Staechelin knew there had been and that matters had reached a point where Mr Staechelin was unwilling to discuss matters further with Mr de Pury.
In the Court of Appeal the trustees mounted what was described as a "sustained" attempt to overturn the decision of Morgan J. on the issue of breach of fiduciary duty and on the issue of trustee decision-making. Although there was no challenge to the decision that there had been consensus as to the payment of commission, the trustees argued that Morgan J. had interpreted and decided the facts incorrectly on the question of breach of fiduciary duty. The central case of the trustees was that Mr de Pury had colluded with Mr Bennett to conceal from the trustees the truth about the previous offer of US$230M and failed to tell the trustees that Mr Bennett's statement that he had "never made a formal offer" was untrue. The suggestion was that Mr Bennett could not risk the truth coming out and needed Mr de Pury to be on side, and that Mr de Pury did not want the truth coming out and putting his commission at risk. The Court of Appeal recorded the submission of the trustees' counsel that Mr de Pury had told "a stonking lie".
Giving the single judgment of court, Lewison. L.J. with whom Lindblom L.J. and Rose L.J. agreed, dealt first with the question of challenges to findings of fact by trial judges. Referring to his own, well-known, judgment in Fage UK Ltd v. Chobani UK Ltd, (5) and to the decisions of the Supreme Court in McGraddie v. McGraddie (6) and Henderson v. Foxworth Investments Ltd, (7) he referred to the "long settled principle" that an appellate court should not interfere with the trial judge's conclusions on primary facts unless it is satisfied that the trial judge was plainly wrong. In this context the words "plainly wrong" confirm that this is an extremely high hurdle. It does not matter that the appellate court considers, with whatever degree of confidence, that it would have reached a different conclusion. What matters is whether the decision under appeal is one that no reasonable trial judge could have reached. Or, as put elsewhere, the test is whether the decision is "rationally insupportable". As Lewison L.J.'s characteristically insightful observations in the Fage case confirmed, the trial "is not a dress rehearsal" but is "the first and last night of the show", and in reaching his decision "the trial judge will have regard to the whole sea of evidence presented to him, whereas an appellate court will only be island hopping."
The trustees argued that Morgan J. had not followed his own guidance. They said he had not taken his findings in relation to the truthfulness of Mr and Mrs de Pury's evidence properly into account when evaluating their honesty on the breach of fiduciary duty issue. Moreover, they said that the Judge ought to have appreciated that it would have made no sense for Mr Bennett to tell the lie they said he did about the earlier offer unless he had procured Mr de Pury's agreement not to reveal the truth. They also said the Judge had not properly explained, if he had taken this into account, how he had done so.
In response to these arguments, Lewison L.J. accepted that it was "a possible analysis" of the facts that Mr de Pury and Mr Bennett had agreed that Mr de Pury would not tell Mr Staechelin that Mr Bennett's assertion that he had not made an earlier offer of USS230M was false. However, bearing in mind the principles referred to above about the role of the appellate court, Lewison L.J. asked himself whether this analysis was so compelling that any other analysis was rationally insupportable or incapable of rational explanation. He was firmly of the view that it was not. It was "fully grounded in the evidence" that Mr de Pury believed that Mr Staechelin knew there had been an earlier offer and Mr Bennett's reference to no earlier "formal" offer was consistent with what both knew to be the case. Furthermore, it was open to the trial judge to find that Mr Staechelin had decided to believe Mr Bennett and disbelieve Mr de Pury such that any further attempt at an explanation by Mr de Pury would have made no difference. Confronted by conflicting and difficult evidence:
it was for the judge to do his best with the material available and to deal with the task of trying to do a jigsaw puzzle when some of the pieces are missing, and many of the others do not precisely fit together.
The first ground of appeal, comprising a direct challenge to Morgan J.'s findings of fact, was therefore rejected. As Lewison L.J. concluded:
Another judge, given the same material, might have come to a different conclusion. But that is a long way from saying that this judge's findings of fact are incapable of rational justification. I would reject this ground of appeal. The judge's findings of fact must stand.
All things being equal this was an interesting but relatively unexceptional application of well-established principles whereby appellate courts will very rarely interfere with the trial judge's evaluation and findings of fact. Undeterred, however, the trustees persisted with two further grounds of appeal, on the issues of breach of fiduciary duty and trustee-decision making.
So far as the appeal in relation to trustee-decision making was concerned, the trustees argued that Morgan J. had misconstrued the trust instrument. They said that the starting point was that trustees under a private trust had to act unanimously, that the trust instrument could make different provision but that, if it does, it must do so expressly and clearly. Therefore, it was said, whilst Article X(C) did empower a decision to be taken by a majority of the trustees, it did not empower two out of three trustees to make a decision without consulting or even informing the third trustee.
The trustees relied on two South African cases, and referred to a comment by the editors of Lewin on Trusts (8) doubting the correctness of Morgan J's first instance decision. This was on the footing that a majority voting provision should not mean that a majority is free to act without reference to the minority; all of the trustees must have the opportunity to participate in a decision. This argument was adopted by the trustees who contended that Article X(C) should be construed as empowering a majority decision only after consultation with the third trustee; they argued that it was only if the third trustee had formally declined to participate in a decision under Article X(A) that the two remaining trustees could take decisions on their own.
The Court of Appeal firmly rejected this ground of appeal. First, it held that it was not properly open to the trustees to advance the majority voting point before Morgan J. and he should not have entertained it. The trustees' pleaded case had been limited to an argument that the agreement of the third trustee was required and that Mr Staechelin and Mr Paisner could not have contracted with Mr de Pury to pay commission without the agreement of Ms McCaffrey. This argument was later deleted by amendment from the pleadings and the majority voting point was not raised until closing submissions. The Court of Appeal agreed that this caused prejudice to Mr and Mrs de Pury since they were deprived of the opportunity of calling an expert on New York law, by which the trust instrument was governed, and the Court held that the point was not open to the trustees on the appeal.
Nonetheless, Lewison L.J. considered the point in any event to be "a bad one". He observed that there is an important distinction between the internal governance of a trust and the external legal relations between a trustee or trustees and a third party dealing in good faith with the trustee or trustees. A provision in the trust instrument, Article III(E), provided as follows: "Exoneration of Third Parties: No person dealing with the Trustees shall be bound to see to the application or disposition of cash or other property transferred to them or to inquire into the authority for or propriety of any action by the Trustees." Lewison L.J. remarked that neither of the South African cases nor the extract from Lewin on Trusts had considered such a provision, and that he regarded it as analogous to the 'indoor management rule' applicable to persons dealing with companies. The purpose of Article III(E) and the indoor management rule is that persons dealing with trustees or companies are entitled to accept decisions at face value. Applying that rule to the trust instrument in the present case, the judgment of Lewison L.J. was that the reasonable reader of the instrument would conclude that it did allow for majority decision-making even if that required a third trustee to be consulted or informed of the prospective decision; the reasonable reader, having regard to Article III(E), would be entitled to infer that this had been done.
This is certainly an interesting adjunct to the law relating to the unanimity of trustee decision-making and the extent to which a trust deed can, by the utilisation of equivalent indoor management provisions, provide for decisions which involve legal relations with third parties to be binding. There would be implications for the personal liability of the trustees. Had the point been open to the trustees it would have led to the personal liability of Mr Staechelin and Mr Paisner only, the Court of Appeal stressing the point, made in Investec Trust (Guernsey) Ltd v. Glenalla Properties Ltd (9) that the rights of a third party are against the trustee or trustees personally and cannot be directly against the trust assets as the trustees do not own those assets beneficially. The only recourse against the trust assets would be by way of subrogation to the trustees' rights of indemnity.
The last ground of appeal was in relation to the allegation of breach of fiduciary duty which in many ways is the most interesting aspect of the decision. Here, the trustees argued that although, on the findings of fact with which the Court of Appeal was not prepared to interfere, Mr de Pury was fobbed off by Mr Staechelin and unable to provide an explanation, he was still in breach of fiduciary duty in not reporting "Mr Bennett's lie" to Mr Paisner. Even if this point was open to the trustees--Morgan J. having held that it was not necessary for Mr de Pury to raise the matter with Mr Paisner or indeed Ms McCaffrey--the Court of Appeal again firmly rejected the argument. Essentially, it was held that either this did not constitute a breach of fiduciary duty at all, or, alternatively, if it did, that "it was not of a character such as to result in the forfeiture of the commission".
The trustees' argument was founded on the decision of the Court of Appeal in Imageview Management Ltd v. Jack, (10) In that case Kelvin Jack, who was Trinidad and Tobago's international goalkeeper, wanted to play professional football in the United Kingdom. He agreed with Mike Berry, and his company Imageview Management Ltd, that Mr Berry would act as his agent and that he would pay 10 per cent of his salary to Mr Berry in the event of a successful placement with a UK club. Mr Berry negotiated a contract for Mr Jack to play for Dundee United for two years. However, he also negotiated a side deal by which he was paid 3,000 [pounds sterling] for obtaining a work permit for Mr Jack, something that he did not tell Mr Jack about. The Court of Appeal upheld the trial judge's decision that this caused all of the commission due to Mr Berry to be forfeit and for Mr Berry to account to Mr Jack for the secret profit from the undisclosed side deal. In doing so, Jacob L.J., with whom Dyson L.J. and Mummery L.J. agreed, said the following:
The law imposes on agents high standards. Footballers' agents are not exempt from this. An agent's own personal interests come entirely second to the interest of his client. If you undertake to act for a man you must act 100%, body and soul, for him. You must act as if you are him. You must not let your own interest to get in the way without telling him. An undisclosed but realistic possibility of a conflict of interest is a breach of your duty of good faith to your client. That duty should not cause an agent any problem. All he or she has to do to avoid being in breach of duty is to make full disclosure. Any agent who is doubtful about his position would do well to do just that--the mere fact that he has doubts will generally be a message from his conscience. The law as to an agent's duty of fidelity goes back a long, long way. Sadly the courts have found it necessary to restate it from time to time. I make no apology for doing so again.
Jacob L.J. then cited three old cases spelling out the high standards which the law imposes on agents: Boston Deep Sea Fishing v. Ansell; (11) Andrews v. Ramsey; (12) ma Rhodes v. Macalister. (13) This led to his conclusion that the draconian remedy of forfeiting all commission is justified.
We are here concerned not with merely damages such as those for a tort of breach of contract but with what the remedy should be when the agent has betrayed the trust reposed in him--notions of equity and conscience are brought into play. Necessarily such a betrayal may not come to light. If all the agent has to pay if and when he is found out are damages the temptation to betray the trust reposed in him is all the greater. So the strict rule is there as a real deterrent to betrayal.
This of course ties into the very nature of fiduciary obligations. As Lord Millett observed in an article entitled 'Equity's Place in the Law of Commerce', (14) which was cited by Lewison L.J. in the appeal: "What distinguishes the role of equity from that of the common law is that equity is proscriptive not prescriptive." In other words, fiduciary law tells the fiduciary what he may not do rather than what he must do.
Notwithstanding this almost universal approach, there may be exceptional cases. Jacob L.J. accepted that certain fact situations involve what has been described as "harmless collaterality". By that is meant some arrangement that is merely collateral to the fiduciary relationship, alternatively cases involving an honest mistake as opposed to any bad faith or dishonesty on the part of the agent. As with any exception, the difficulty lies in being able to predict whether the facts are such as to involve some mere collateral act or omission or one not involving any bad faith.
In rejecting the trustees' argument, the appeal in the present case was analysed as involving just such an exception. Three important planks in the reasoning were the decisions of the Court of Appeal in Keppel v. Wheeler, (15) of the Privy Council in Kelly v. Cooper (16) and the seminal modern judgment of Millett L.J. on breach of fiduciary in Bristol & West Building Society v. Mot hew. (17)
In Keppel estate agents were engaged to find a buyer for a block of flats. They obtained an offer which their client accepted. However, before contracts exchanged, they received a higher offer. They did not pass that offer on to their client. They argued they did not have to because, having found a willing buyer, their agency had ended. The Court disagreed and held that the agency continued until contracts were exchanged, but the Court stopped short of depriving the estate agents of their commission. The reason for this was that it was held that the failure of the estate agents to pass on the offer did not involve any bad faith; they genuinely believed that they had fulfilled their duty to their principal and did not understand that only a formal exchange of contracts brought their duty to an end. It was therefore regarded as a case of breach of contract, at most, not a breach of fiduciary duty, or, even if the latter, that it did not justify the remedy of forfeiture of all of the commission.
In Kelly the Privy Council rejected the proposition that forfeiture of commission was justified in cases of an inadvertent breach of duty by an agent. As Lord Browne-Wilkinson said: "... even if a breach of fiduciary duty by the defendants had been proved, they would not thereby have lost their right to commission unless they had acted dishonestly."
In Mothew, Millett L.J. famously said that in the context of an agent's failure to pass on relevant information the Court will:
jealously scrutinise the facts to ensure that there has been nothing more than inadvertence, but there can be no justification for treating an unconscious failure as demonstrating a want of fidelity.
Returning to the facts of the case, Lewison L.J. noted that on the Judge's findings Mr de Pury was not disloyal, but had attempted to communicate with Mr Staechelin. He further observed that, whereas in a case involving a secret profit it is easy to conclude that an agent has been disloyal, where the alleged breach of duty comprises a failure to pass on information it is not one which will disentitle a fiduciary to his remuneration unless it is accompanied by bad faith or dishonesty. He agreed with counsel for Mr and Mrs de Pury that "a failure to pass on information does not stand on the same footing as a case of secret profit". Since the claim that Mr de Pury had conspired with Mr Bennett failed on the facts and it was not alleged that his omission to contact Mr Paisner had been in bad faith, the argument that there had been a breach of fiduciary duty in that respect such as to disentitle Mr and Mrs de Pury to any commission had to fail. He expressed his conclusion as follows:
It does not matter for present purposes whether the correct analysis is that there was no breach of fiduciary duty at all; or whether there was such a breach, but it was not of a character such as to result in a forfeiture of the commission. Either way, an agent will not lose his commission if he has neither been dishonest nor acted in bad faith.
The difficulty with the trustees' appeal was that, however strongly they felt that Mr de Pury had told a "stonking lie", once it had been held on the facts that Mr de Pury had not done so and there were, in effect, innocent factors to explain why he did not tell Mr Staechelin that Mr Bennett's comments were untrue, it was not going to be possible to say that the failure to contact Mr Paisner was activated by bad faith. The appeal is therefore a useful addition to the law on the fiduciary duties of agents as illustrating that not every breach of duty will give rise to the forfeiture of commission. Whilst that result will almost always follow in cases of obvious disloyalty arising out of a conflict of interest which an agent could not possibly fail to appreciate, and will obviously follow in cases of secret profits, there may be exceptions, of which this was one, where the omission to pass on information has an innocent explanation. The outcome should not be regarded as a softening of the Court's concern to enforce the strict duties of agents by forfeiting their remuneration. The risk of that outcome in the event of an agent consciously allowing his own interests to come before those of the person on whose behalf he acts remains. As such, the words of Jacob L.J. in Imageview should remain compulsory reading for all art industry intermediaries.
Michael Bowmer, Barrister, 4 New Square, Lincoln's Inn, London.
(1)  EWCA Civ. 817.
(2)  EWCA Civ. 62.
(3) (2018) XXIII Art Antiquity and Law 77.
(5)  EWCA Civ. 5.
(6)  1 W.L.R. 2477.
(7)  1 W.L.R. 2600.
(8) (19th edn, Sweet & Maxwell, 2018).
(9)  2 W.L.R. 1465.
(10)  EWCA Civ. 62.
(11) (1888) 39 Ch. D. 339.
(12)  2 K.B. 635.
(13) (1923) 29 Com. Cas. 19.
(14) (1998) L.Q.R. 214.
(15)  1 K.B. 577.
(16)  A.C. 205.
(17)  1 Ch.F 1.
|Printer friendly Cite/link Email Feedback|
|Publication:||Art Antiquity & Law|
|Date:||Jul 1, 2019|
|Previous Article:||EXAMINING THE POLICY IMPLICATIONS OF THE CASSIRER DECISION.|
|Next Article:||PROVING CONTEMPORARY ART FORGERIES: AN ANALYSIS OF R. v. GANT AND SIDDIQUE.|