From Sotheby’s to Character Assassination: Provenance Research, Market Expertise, and Institutional Responsibility in the Case of Turin MS E.V.5

 

by Carla Rossi

 

Watch the Full Video-Documentary Evidences on YouTube https://youtu.be/oDuQiuG0IQE?is=dI_3brVvMajyyF6Q

Abstract

This article examines the case of three illuminated leaves stolen in 1979 from manuscript E.V.5 at the Biblioteca Nazionale Universitaria di Torino (BU-TO) and subsequently offered at Sotheby’s London in 2013 and 2015. Through a documentary reconstruction of the case, it analyses provenance research, due diligence, and the professional responsibilities of participants in the manuscript market. The surviving foliation, the rarity of the textual tradition, and official photographic documentation made it possible to identify the leaves and return them to the BU-TO in 2018. The article distinguishes independent scholarly expertise from commercial expertise exercised within a transaction and considers the conflicts that may arise when academic authority is also deployed in the service of an auction house, dealer, or commercial gallery. It then examines the campaign of personal and professional delegitimisation that followed the author’s provenance investigations, together with the institutional responses of the University of Zurich and the Swiss National Science Foundation. The E.V.5 case demonstrates that protecting cultural heritage requires both effective scrutiny of the market and safeguards for researchers who document the circulation of stolen or unlawfully dismembered objects.

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Keywords

Medieval manuscripts; Provenance; Due diligence; Stolen cultural property; Antiquarian market; Conflicts of interest; Character assassination; Research integrity

 

In January 1979, three illuminated leaves were stolen from manuscript E.V.5 at the Biblioteca Nazionale Universitaria di Torino (hereinafter “BU-TO”). Produced for the French court in the early sixteenth century, the manuscript is one of only two known witnesses to the works of Raoul Bollart. It preserves the Ecloga de victoria Ludovici XII Galliarum Regis contra Venetos anno MDIX and the Otium litterarium: Regni pauperis legatio ad unumquenque divitem; the other witness, MS Lat. 97 at the Bibliothèque de Genève, was produced for the author himself. The 1979 theft therefore mutilated a manuscript of exceptional importance, both for the quality of its decorative programme and for the rarity of the textual tradition to which it belongs.

The stolen leaves, corresponding to fols. 9, 11, and 20, contained some of the manuscript’s most significant miniatures (Figs. 1–3).

Following the reporting of the theft, photographs of the missing leaves were published in the Bollettino delle opere d’arte trafugate issued by the Comando Carabinieri Tutela Patrimonio Culturale (TPC).[1]

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Fig. 1. Fol. 9v as it appears in the TPC’s Leonardo Database.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

​Fig. 2. Fol. 11r as it appears in the TPC’s Leonardo Database.

 

 

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Fig. 3. Fol. 20v as it appears in the TPC’s Leonardo Database.

 

The consultation register held by BU-TO (Fig. 4) records that the manuscript had been requested for consultation by a student from Turin in the days immediately preceding the discovery of the theft.

For thirty-five years, the whereabouts of the three illuminated leaves remained unknown. They eventually resurfaced together on the London antiquarian market, where Sotheby’s offered them in two successive auctions: Medieval and Renaissance Manuscripts, London, 2 July 2013, lots 19–21, and Medieval and Renaissance Manuscripts, London, 7 July 2015, lots 49–51.[2][3]

The length of time between the theft and the leaves’ recovery requires two distinct issues to be kept separate: the criminal prosecution of the original theft and the verification of the stolen objects’ provenance. The longer the undocumented interval between an object’s last confirmed location and its reappearance on the market, the more exacting the reconstruction of its provenance should be.

At the time of the theft, Italian law did not provide for a distinct criminal offence specifically addressing the theft of cultural property. The particular criminal-law character of offences against cultural heritage was comprehensively recognised only by Law No. 22 of 9 March 2022, which inserted Title VIII-bis, Offences against Cultural Heritage, into the Italian Criminal Code and introduced, among the new offences, Article 518-bis, Theft of Cultural Property.[4]

Against this legal background, the case of manuscript E.V.5 provides a particularly valuable basis for defining the due diligence applicable to the trade in manuscripts and miniatures.

Although Article 4 of the 1995 UNIDROIT Convention operates within its own specific field of application, it formulated a standard that has had a wider influence on market conduct. The purchaser’s diligence must be assessed in light of all the circumstances of the acquisition, including the character of the parties, the price paid, consultation of any reasonably accessible register of stolen cultural objects, the documentation and information that could reasonably have been obtained, and any other step that a reasonable person would have taken in the same circumstances.[5]

The model established by the UNIDROIT Convention presupposes active enquiry: the object’s history must be investigated, the consistency of the information supplied by the transferor assessed, any gaps in the chain of ownership identified, and any circumstances requiring further scrutiny – whether because of the nature of the object or the manner in which it appeared on the market – properly examined.[6]

In the case of illuminated leaves originating from dismembered manuscripts, this requirement directly engages the specialist’s expertise. A manuscript fragment, or even an intact leaf, does not become an isolated object merely because it is presented as such at the time of sale. Its material features preserve multiple indications of its former place within a codicological whole: the dimensions and proportions of the support, ruling, mise en page, early and modern foliation, textual continuity, palaeographical features, decoration, evidence of binding or sewing, trimmed margins, iconographic correspondences, and relationships with other known leaves. Taken together, these elements may make it possible – sometimes with considerable precision – to reconstruct the manuscript from which the leaf or miniature originated.[7]

It follows that, in the market for dismembered manuscripts, due diligence necessarily has a philological, palaeographical, and codicological dimension. The leaves stolen in Turin were not three miniatures originally conceived as autonomous objects; they were folios belonging to a manuscript held by a public library and physically separated from the volume through an unlawful act. Their appearance on the market therefore raised a question logically prior to any art-historical attribution: from which manuscript had they come, and through what chain of transactions had they entered the consignor’s possession?

The case therefore shifts the enquiry from mere knowledge of illicit origin to the quality of the checks that could reasonably be required. The question is not only what a market participant actually knew at the time of sale, but what that person, given their professional capacity and the evidence available, was required to verify. It is precisely in the space between actual knowledge and knowledge obtainable through diligent enquiry that provenance research ceases to be ancillary to the commercial description and becomes an integral part of the intermediary’s professional responsibility.

The history of the leaves stolen in 1979 thus involved actors from two fundamentally different spheres: on the one hand, the Comando Carabinieri Tutela Patrimonio Culturale, Interpol, librarians, conservators, and academics engaged in identifying, studying, and recovering the stolen objects; on the other, the participants in the international antiquarian market through which the three leaves were once again offered for sale.

The distinction is not merely terminological. In the properly scholarly sense, an expert is a researcher whose knowledge is exercised within a university or an academic-level research institution, according to transparent methods and subject to critical scrutiny by the scholarly community. Crucially, such an expert has no financial or professional interest in the sale, marketability, or commercial valuation of the object under examination. Independence from the transaction is therefore not an incidental personal quality, but a constitutive condition of scholarly expertise.

By contrast, in auction-house practice, the title “specialist” denotes a professional function performed within the market itself. A consultant or cataloguer commissioned to prepare an expert assessment contributes directly to the commercial process: the attribution, description, and proposed provenance of an object affect its marketability, estimated value, and prospects of sale. This does not necessarily exclude technical knowledge, but it places that knowledge within an  economic framework fundamentally different from independent academic research. Treating the independent scholar and the market professional as equivalent forms of “specialist” therefore obscures the decisive distinction between expertise directed towards the production of verifiable knowledge and expertise deployed within a transaction from which the market actors involved may derive an economic benefit.

The position becomes still more complex where an art historian affiliated with a university or research institution also acts, outside that institutional role, as a paid expert or consultant for an auction house, dealer, or commercial gallery. Academic status does not neutralise the commercial nature of the latter function, nor should an institutional affiliation be used to confer an appearance of scholarly independence upon an assessment prepared for the market. Such a dual role may give rise to an actual, potential, or apparent conflict of interest, particularly where an opinion concerning attribution, authenticity, provenance, or marketability may affect the financial interests of the parties involved.

In these circumstances, professional integrity requires full disclosure of the mandate, remuneration, and relevant commercial relationships, a strict separation between institutional research and market activity, and, where necessary, recusal. The decisive question is therefore not simply whether the individual possesses academic qualifications, but in what capacity the opinion was given, for whose benefit it was prepared, and whether the expert was genuinely independent of the transaction.

This distinction becomes particularly sensitive where the expert assessment concerns illuminated leaves separated from their original manuscript. In such cases, a scholarly reconstruction of provenance may have consequences directly opposed to the commercial interest in completing the sale: identifying the manuscript of origin may reveal theft and the handling of stolen property. Under the applicable terms, the auction house derives commissions from completion of the sale, calculated on the hammer price and on amounts payable by the parties; the specialist may also receive remuneration connected with that process. The work of specialists and cataloguers therefore forms part of a commercial organisation whose revenue is directly linked to the sale of objects. A documented provenance may strengthen value; a problematic provenance may require further enquiries, lead to withdrawal of the lot, or prevent the sale altogether. Attribution and provenance research cannot therefore be subjected to different standards of rigour. It would be incompatible with proper due diligence to deploy specialist expertise in making attributions and art-historical reconstructions capable of increasing the value of a lot while failing to apply that same expertise to evidence capable of undermining its marketability. Anyone who employs specialist knowledge to assign an origin, chronology, and cultural context to an object – and thereby, indirectly, an economic value – must apply the same rigour to evidence capable of reconstructing its material and ownership history. In the case of the E.V.5 leaves, the issue was therefore neither the prestige attributed to the cataloguer nor his public self-presentation as a “manuscript specialist”, but the function actually performed within the commercial process and the responsibility arising from the use of expertise to present cultural objects to the market before their provenance had been properly established.

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The Failure to Exercise Due Diligence

According to information supplied by Dr David Goldthorpe, Senior Director of Sotheby’s Department of Books and Manuscripts, the three leaves remained unsold at the auction of 2 July 2013, for which Timothy Bolton acted as specialist and Christopher de Hamel as scholarly adviser. Peter Kidd, who had already worked for years as a consultant to the auction house and had been involved in transactions comparable to the resale of the leaves from the Turin manuscript, assumed responsibility in 2015 for the Medieval and Renaissance Manuscripts sale and its accompanying catalogue. His role must therefore be examined primarily in relation to the second attempt to commercialise the three leaves, in light of the due-diligence standards outlined above.[8]

The scholarship published before the two auctions had already made clear that only two manuscripts, both richly decorated, transmitted Raoul Bollart’s works: the Geneva manuscript, preserved intact, and Turin manuscript E.V.5, which had been mutilated for profit in 1979. Moreover, when the three leaves were offered for sale, they still retained the manuscript’s original foliation in their upper right-hand margins (Figs. 8–10).

The correspondence between the contents of the leaves offered at Sotheby’s and the three lacunae in the Turin manuscript therefore made it possible to establish their illicit provenance with certainty.

The central question is therefore not whether the cataloguer had been expressly informed that the leaves were stolen – a circumstance requiring independent proof –  but whether the exercise of the professional diligence reasonably expected of a medieval-manuscript “specialist” should have led to the identification of the Turin manuscript and, consequently, to suspension of the sale pending further enquiries.

Photographs of the stolen leaves had, in fact, been made public as early as 1982 in an official TPC publication specifically intended to facilitate the identification and recovery of stolen cultural property.

In light of the criteria outlined above, the procedures followed for the 2015 auction may first be assessed through the catalogue itself, which records the depth of the specialist’s examination of the three leaves. The entries correctly identified the texts and their author, reconstructed the political context of the war against Venice, situated Bollart within the literary milieu of the grands rhétoriqueurs, proposed an attribution for the decorative programme, and identified MS Lat. 97 at the Bibliothèque de Genève as the necessary comparator for interpreting the leaves.

The descriptions reveal specialist knowledge of the material that was far from superficial. Precisely for that reason, the catalogue’s failure to mention manuscript E.V.5 at the Biblioteca Nazionale Universitaria di Torino is especially significant. The omission did not concern a witness peripheral to the enquiry; it concerned the other manuscript transmitting the same works by Bollart and, more importantly, the manuscript from which the three leaves offered for sale had been physically removed.

In particular, the person responsible for the descriptions in the London auction house’s 2015 catalogue demonstrated clear knowledge of the material, the textual tradition, and the rarity of Raoul Bollart’s works. Yet the entry mentioned only the Geneva manuscript, without any reference to the Turin manuscript mutilated in 1979.

The omission appears particularly serious because the catalogue text instead emphasised the exceptional character of the leaves and the existence of a hitherto unknown second copy of the manuscript, thereby constructing a narrative capable of increasing their antiquarian and collecting value. The catalogue stated:

 

The Geneva manuscript was previously thought to be unique: the present leaves are the only evidence that a second copy existed; presumably one copy was made for the author and another was a presentation copy for the King. The Geneva manuscript has neither dedication nor royal arms. The execution of the present leaves is superior to the style of the Geneva copy; they may well be from the presentation copy.[9]

 

The assertion that the leaves constituted “the only evidence that a second copy existed” cannot be reconciled with the existence of manuscript E.V.5. The issue goes beyond the bibliographical accuracy of the entry. Identification of the Turin witness would also have radically altered the reconstruction of the lots’ provenance: rather than appearing as isolated evidence of an otherwise unknown second copy, the three leaves would have been recognised as material corresponding to lacunae in a manuscript held by an Italian state library and mutilated in 1979.

The asymmetry between the depth of the attributional and art-historical enquiry and the verification of provenance is particularly evident here. The material and textual features of the leaves were examined closely enough to enable the cataloguer to propose hypotheses concerning patronage, the intended recipient of the manuscript, and the comparative quality of its decoration. Yet those same features, considered together with the scholarship on the transmission of Bollart’s works and the foliation still visible on the leaves, would have made it possible to trace them back to the Turin manuscript.

It is within this asymmetry that the due-diligence issue arising from the 2015 auction must be located. Specialist expertise cannot operate solely in the service of attribution and commercial enhancement: where the same evidence on which the attribution rests also makes it possible to reconstruct the original codicological context, verification of provenance forms part of the same professional responsibility. In the present case, the catalogue records an enquiry sufficiently detailed to identify the exceptionally rare textual and cultural context of the leaves, yet it does not acknowledge the other witness to Bollart’s works – namely, the very manuscript from which the leaves had been removed.

 

Recovery and Restitution

Following the 2015 auction, the three illuminated leaves were located in Brussels as a result of an extended investigation coordinated by the Genoa TPC Unit in cooperation with Interpol.

According to the official documentation, the detailed descriptions prepared by the library immediately after the 1979 theft proved decisive. In November 2018, the miniatures were formally returned to the Biblioteca Nazionale Universitaria di Torino, which arranged for their reintegration into the manuscript. The volume was restored by the Book Conservation Laboratory of the Abbey of Saints Peter and Andrew at Novalesa, with joint funding from Rotary, Inner Wheel Torino Castello, and Soroptimist International of Turin.

From Recovery to Retaliation

The recovery of the three Turin leaves might appear to mark the conclusion of the E.V.5 case. From the perspective of cultural-property protection, however, it marked the beginning of a second and equally significant phase. Once the circumstances of the leaves’ commercial circulation, the omissions in their auction descriptions, and the professional roles of the persons involved began to be examined publicly, the provenance enquiry ceased to concern the objects alone. It was followed by a sustained campaign directed against the professional credibility and personal reputation of the researcher who had documented the case.

In 2022, after more than thirty years of philological and codicological research on dismembered manuscripts and of reporting illuminated leaves originating from stolen cultural property to the Comando Carabinieri Tutela Patrimonio Culturale, the author of this article began publicly documenting the role of dealers, intermediaries, auction-house consultants, and academic experts in the international circulation of mutilated manuscripts. In August 2022 she published Biblioclasm & Digital Reconstruction: Eleven Scattered Manuscripts Digitally Reassembled through the Wayback Recovery Method and submitted to the TPC documentation concerning persons involved in the dismantling and commercialisation of illuminated medieval manuscripts.

Between December 2022 and January 2023, Peter Kidd, the Sotheby’s consultant who had prepared the 2015 catalogue descriptions of the leaves stolen from manuscript E.V.5, began publishing a series of allegations against the author’s scholarly work. The chronological proximity between the provenance investigations, the submission of documentation to the competent authorities, and the beginning of the attacks does not by itself establish motive. It nevertheless forms part of the documentary sequence and requires the allegations to be examined in the context in which they arose.

That context was not without precedent. Kidd had previously participated in public accusations against Giovanni Mazzarelli (see note 8), an Italian collector who had acquired through Sotheby’s manuscripts later identified as having been stolen from Italian institutions. The subsequent investigations and judicial proceedings led to the recovery of the manuscripts and to acknowledgements of responsibility connected with their handling and commercialisation. The recurrence of reputational accusations in connection with provenance disputes therefore warrants examination as an aspect of the market history of the objects concerned, rather than as an unrelated personal controversy.

 

Character Assassination as a Response to Provenance Research

The campaign against the author rapidly extended beyond scholarly criticism. Online publications and social-media posts alleged plagiarism and academic misconduct; emails repeating those allegations were sent to colleagues, students, publishers, research institutions, and funding bodies. Digital files from Open Access publications were presented in altered or misleading contexts in support of accusations that were then reproduced across different platforms. False obituaries announcing the author’s death by suicide were also circulated online.

The conduct became increasingly intrusive. Photographs of the mailbox at the author’s private residence were published, members of her family were mentioned, and colleagues or collaborators who publicly supported her were themselves subjected to hostile communications. Her legal representative received personal threats and ultimately withdrew. Considered individually, some of these acts might be described as online abuse; considered together, and in their chronological and professional context, they constitute a sustained attempt to damage a scholar’s credibility, isolate her from her professional community, and displace attention from the provenance evidence she had produced.

Gaudenz Freuler, formerly Titularprofessor at the University of Zurich and also active as an expert for the antiquarian market, publicly intervened in the controversy surrounding the author’s research. The combination of these academic and commercial functions is relevant to the distinction drawn above between independent scholarly research and expertise exercised within a commercial transaction.

In documentation submitted to the Comando Carabinieri Tutela Patrimonio Culturale, the author drew attention to an expert assessment prepared by Freuler and used in connection with the presentation and sale by the Zurich auction house Koller, in 2015, of a leaf attributed to the so-called Antiphonary D of Castelfiorentino. The submission further indicated that the object corresponded to material documented in the records of the TPC. These circumstances raise questions concerning the provenance checks undertaken before the sale and the relationship between academic authority and commercial expertise. They do not, in themselves, establish that Freuler knew of any unlawful provenance, a matter that would require determination by the competent authorities.

The relevance of these circumstances does not depend upon questioning the academic qualifications of the person concerned. The issue is the capacity in which the opinion was given, the purpose for which it was prepared, the disclosure of relevant commercial relationships, and the extent to which institutional authority may have enhanced the credibility of an assessment produced for the market. These are questions of research integrity and conflict of interest, not matters of personal animosity.

 

Institutional Responses and the Asymmetry of Scrutiny

The institutional handling of the controversy forms part of the same history. Documentation concerning the provenance of the objects, the commercial affiliations of the persons involved, and the potential conflicts of interest arising from their dual roles was submitted to the University of Zurich and to the Swiss National Science Foundation. The responses of those institutions did not subject those matters to a level of scrutiny equivalent to that applied to the allegations advanced against the author. Institutional weight was consequently accorded to accusations promoted by Kidd and supported by Freuler, while the market relationships and provenance evidence underlying the dispute remained substantially outside the enquiry.

Where allegations originate from persons whose own activities or commercial relationships form part of the subject under investigation, procedural fairness requires examination not only of the accusations made, but also of the interests, conduct, evidentiary position, and professional capacity of those making them. Treating the matter primarily as a controversy concerning the researcher, without equivalent consideration of the provenance documentation that occasioned it, risks allowing institutional procedures to become an extension of the process of delegitimisation.

The judgment of the Swiss Federal Administrative Court of 7 January 2026 in case B-2940/2024 is therefore of particular importance. By annulling the administrative measures adopted in connection with the Swiss National Science Foundation project and rejecting the plagiarism narrative of Peter Kidd on which they had been based, the judgment removed one of the principal institutional foundations of the campaign. It did not, however, resolve the broader question of why allegations arising from actors implicated in the underlying provenance controversy had been accepted without a correspondingly rigorous assessment of their interests and of the documentary record.

The issue is not whether universities or funding bodies must endorse the conclusions of every researcher who reports suspected wrongdoing. It is whether they apply equivalent evidentiary standards to all parties and preserve the distinction between independent research, commercial expertise, and reputational advocacy. Institutional protection of academic integrity cannot depend upon the status of the persons concerned. It requires an impartial examination of their respective functions, interests, conduct, and claims.

 

Conclusions

The case demonstrates that, in the market for early manuscripts and illuminated leaves, expert assessment is not a form of scholarly activity neutral in relation to the economic transaction it serves. A catalogue entry helps construct the identity of an object, determine its attribution and provenance, support its estimate, and ultimately make its sale both possible and profitable. A consultant or cataloguer working for an auction house therefore occupies a position within an economic chain from whose successful completion the auction house—and, depending on the applicable contractual arrangements, the professionals involved—may derive an economic benefit.

For that very reason, the accuracy of an expert assessment concerning provenance cannot be treated as a secondary aspect of the description. Where available and verifiable information is capable of revealing that an object originates from a theft, omitting that information—or constructing an alternative account that presents the object as independently marketable—may directly affect both the possibility of placing it on the market and the economic value attributed to it. In such circumstances, the issue extends beyond an attributional error or the entry’s scholarly inadequacy and concerns the concrete function performed by the expert assessment in the object’s circulation.

From the perspective of criminal law, it must be emphasised that inadequate due diligence may need to be distinguished from the knowing facilitation of the circulation of property derived from a criminal offence. The latter possibility, if the objective and subjective elements required by law were established, would raise issues falling within the offences governing the receipt of stolen cultural property. The relationship between expertise, economic interest, and provenance research thus lies at the centre of the E.V.5 case: anyone professionally involved in identifying, enhancing the value of, and rendering a cultural object marketable cannot separate the knowledge used to construct its economic value from that required to verify its lawful provenance. The case also demonstrates the fundamental importance of documentation produced by public institutions when a theft is reported – a task that unfortunately remains difficult where diocesan libraries are concerned. In the present case, more than thirty years later, the photographs published by the Comando Carabinieri Tutela Patrimonio Culturale in 1982 proved decisive in recognising the miniatures when they resurfaced on the international antiquarian market. This confirms that an accurate record of a cultural object’s material characteristics may, over time, become the most effective instrument for its recovery.

The subsequent campaign of character assassination demonstrates that provenance research may expose scholars to pressures extending far beyond ordinary academic disagreement. Effective protection of cultural heritage therefore requires institutions not only to preserve objects and investigate their ownership history, but also to assess with equal rigour the interests of market participants and the allegations directed against those who document potentially illicit circulation. Protecting the integrity of provenance research is itself a condition of protecting the cultural objects to which that research gives back their history.

The history of manuscript E.V.5 is a reminder that stolen cultural objects do not cease to belong to the history of the institutions that preserved them. Even when dispersed, commercialised, and withheld from public access for decades, they continue to bear traces of their identity and provenance. Reconstructing those traces is one of the most important tasks of historical research and one of the most effective means of protecting cultural heritage.

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NOTES

[1]Available, together with all the other TPC bulletins, at: https://tpcweb.carabinieri.it/SitoPubblico/home/contenuti/bollettini

[2]Sotheby’s, Medieval and Renaissance Manuscripts, London, 2 July 2013, sale L13240, lots 19–21; online catalogue available at: https://www.sothebys.com/en/auctions/ecatalogue/2013/medieval-renaissance-manuscripts-l13240.html

[3]Sotheby’s, Medieval and Renaissance Manuscripts, London, 7 July 2015, sale L15240, lots 49–51; online catalogue available at: https://www.sothebys.com/en/auctions/2015/medieval-renaissance-manuscripts-l15240.html?locale=it

[4]Law No. 22 of 9 March 2022, Disposizioni in materia di reati contro il patrimonio culturale [Provisions concerning offences against cultural heritage], Gazzetta Ufficiale della Repubblica Italiana, no. 68, 22 March 2022, in force from 23 March 2022, Art. 1; see Italian Criminal Code, Art. 518-bis, Furto di beni culturali [Theft of cultural property]. The provision punishes the theft of cultural property by imprisonment for a term of two to six years and a fine of EUR 927 to EUR 1,500; in the aggravated circumstances specified in the second paragraph, the penalty is imprisonment for four to ten years and a fine of EUR 927 to EUR 2,000.

[5]UNIDROIT, Convention on Stolen or Illegally Exported Cultural Objects, Rome, 24 June 1995, Art. 4(4). Among the criteria for assessing due diligence, the provision expressly refers to “all the circumstances of the acquisition”, the character of the parties, the price paid, consultation of any reasonably accessible register of stolen cultural objects, the information and documentation that could reasonably have been obtained, and any other step that a reasonable person would have taken in the circumstances.

[6]See UNIDROIT, Convention on Stolen or Illegally Exported Cultural Objects: Explanatory Report, commentary on Art. 4(1), which relates due diligence to the need to conduct serious enquiries into an object’s provenance and expressly connects the “ought reasonably to have known” criterion with the need to increase vigilance among purchasers and market participants.

[7]On the methodology for identifying, reassembling, and reconstructing the provenance of the membra disiecta of medieval manuscripts—based on the combined analysis of codicological, palaeographical, textual, iconographic, heraldic, and documentary evidence, together with systematic comparison with auction catalogues, public and private collections, and photographic records—see C. ROSSI, Biblioclastia a scopo di lucro e culto feticistico dei frammenti di manoscritti medievali, “Studj romanzi”, XVIII, 2022, pp. 161–196; EAD., Introduction – Biblioclasm & Digital Reconstruction, “Theory and Criticism of Literature & Arts”, VI/1, 2022, pp. 9–20; EAD., Isabelle Boursier’s Book of Hours: A Dismembered Manuscript from Mary Benson’s Collection, Newcastle upon Tyne, Cambridge Scholars Publishing, 2024; C. ROSSI – A. MARTIN, Digital Reconstruction of a Dismembered Book of Hours Illuminated by Robert Boyvin, Newcastle upon Tyne, Cambridge Scholars Publishing, 2024; C. ROSSI, The 1879 Theft of Royal MS 16 E VIII from the British Museum, Newcastle upon Tyne, Cambridge Scholars Publishing, 2024; EAD., Biblioclasm for Profit: The Legal Implications of Dismembering Western Medieval Illuminated Manuscripts, “Harvard Art Law Review”, I/1, 2025, pp. 97–167.

[8]See https://mazzarelligiovanni.jimdofree.com/. Several Italian illuminated manuscripts purchased by Giovanni Mazzarelli in 1979 in the course of a private transaction arranged by Sotheby’s London were subsequently found to originate from thefts at Italian libraries and institutions. Peter Kidd was already active in that context as a Sotheby’s cataloguer and consultant; his name appears in documentation concerning the handling of the case and the ensuing protracted defamatory campaign against Mazzarelli, whom the auction house accused of personally stealing in Italy manuscripts that he had in fact purchased from Sotheby’s. Subsequent investigations led to the recovery of the manuscripts by the Italian authorities, and the matter resulted in judicial proceedings that compelled Sotheby’s to acknowledge its responsibilities in the handling and sale of cultural objects stolen in Italy. Peter Kidd also appears in more recent events. Since December 2022, he has authored a lengthy series of defamatory and harassing publications directed against the author of this article. A detailed reconstruction of these events lies outside the scope of the present article, but may be found in Jordi Puig’s recently published volume, The ReceptioGate Affair 2026: New Evidence on Peter Kidd, the Sotheby’s Sale of Stolen Leaves from Turin MS E.V.5, and the Defamation Campaign that Followed, Éditions Pigouchet, Paris, 2026.

[9]See both https://www.sothebys.com/en/auctions/ecatalogue/2015/medieval-renaissance-manuscripts-l15240/lot.49.html and the PDF catalogue of the auction.

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