The PALU Secretariat is pleased to present this three-part research report, the culmination of several months of consultations, research, and drafting. This project reflects the spirit of our organization. As a Pan-African institution, we firmly believe that the right to culture and access to cultural heritage are essential components of the African identity and experience.

This belief underpins our focus on the restitution and reparations movements. While these two movements have often developed along distinct paths, their interconnectedness cannot be denied. This intersectionality of purpose makes the timing of this publication particularly significant, especially in light of the African Union’s Theme for 2025: Justice for Africans and People of African Descent Through Reparations.

We must also recognize that the conversation around the restitution of African cultural heritage is not new. For decades, African voices have called for the return of cultural artefacts wrongfully taken during colonial rule and historical conflict. While those before us have made notable steps in advocacy and dialogue, most of the continent’s cultural heritage remains housed in European and North American institutions, far from the communities to whom it rightfully belongs. This continued disconnect continues to impact identity, memory, and access to heritage for millions across the continent.

In response, this project was conceptualized to explore the extent to which legal frameworks, both national and international, can provide effective pathways for the restitution of African cultural heritage. Our initial goal was to deepen our understanding of the legal instruments applicable to Africa’s unique historical and cultural context. This inquiry led us to refine the project’s scope geographically, as reflected across the three parts of the report.

Part I provides an overview of the legal landscape and potential restitution pathways.

Parts II and III focus on select European countries and American states, analyzing the relevant statutory and case law frameworks

Our objective is not only to offer legal analysis, but also to provide practical reflections that can inform policy, enrich academic and legal discourse, and support advocacy and litigation strategies across the continent. Each part of the report identifies potential litigation pathways while also emphasizing the importance of alternative mechanisms such as diplomacy and mediation.

The questions, challenges and solutions explored in these pages are both urgent and ongoing and they call for the active participation of all who care about justice, accountability, and institutional progress.

We express our gratitude to the researchers, contributors, reviewers, members, and supporting institutions whose expertise and dedication made this report possible. We hope this publication will serve as a resource for further dialogue, collaborative scholarship, and tangible progress in the cultural restitution agenda.

We invite you to engage with its findings and to join PALU in advancing the next phases of Africa’s cultural restitution efforts.

Sincerely,

Editors

Ruth Osaretin Ogbewekon

Project Lead- Restitution and Reparations in Africa, PALU

François GODBOUT

Director of Programmes, PALU