How Europe stole Africa.

Chapter One: Capture begins

Nowadays, the sleepy town of Chibok in northern Nigeria is notorious for the kidnapping of 276 children by Boko Haram. But go back 115 years and this tiny farming community perched atop a hill fought one of the greatest resistances to British colonization.

In November 1906, around 170 British soldiers launched what that country’s parliament called a “punitive expedition” against the town for carrying out annual raids along British trade routes in Borno state.

In defence, during an 11-day siege, Chibok townsmen shot poisoned arrows at the soldiers from hideouts in the hills.

The fiercely independent “small Chibbuk tribe of savages”, as they were described in a report presented to Britain’s parliament in December 1907, had been “the most determined lot of fighters” ever encountered in what is now modern-day Nigeria. It took British forces another three months to annex Chibok, and only after they discovered their natural water source and “starved them out”, the report said.

The arrows and spears the Chibok townsmen had used against the British were then collected and sent to London where they are held in storage today. But curator labels available online about the background of the items at the British Museum – which holds around 73,000 African objects – make no mention of how the spears got there, nor of the town’s resistance against “punitive” colonization.

Shrouded in a storeroom, those arrows point to a wider conflict unfolding about artefacts looted from Africa during wars and colonization and held in Western museums.

While many Western curators defend their collections as “universal”, representing the art of the world regardless of how they were acquired, critics suggest they have not done enough to accurately present the complex histories of the objects that were taken.

Historian Max Siollun recounts Chibok’s capture in his book, What Britain did to Nigeria, which examines the legacy of Nigeria’s violent colonisation in its rapidly expanding modern crisis. He believes historical narratives – largely written by Europeans – were deeply flawed, neglecting “a much more interesting and deeper history”.

“It is very dangerous to rely on the victor’s account as the sole account of history,” he says. “There is a proverb about this … the tale of the hunt will always be the hunter’s tale until the lion learns how to tell its story.”

Critics also accuse Western museums of participating in a gross abuse of power.

“Museums were definitely devices that helped to shape colonialism and stories of conquests and the legitimising of the conquests,” says Ayisha Osori, director of the Open Society Initiative for West Africa (OSIWA), headquartered in Senegal. She is co-leading a four-year, $15m initiative by the Open Society to help nations get back their cultural treasures held abroad.

“If we use the Benin kingdom in Nigeria, the Dahomey kingdom in Benin [Republic] and the Ashanti kingdom in Ghana – a lot of violence was how these things were taken,” she says.

Six decades on from independence, African governments are actively seeking the return of stolen artefacts. Historically, European authorities refuted claims for return on the basis that they could not determine who the original owners were. Other excuses, according to Abba Isa Tijani, the director general of Nigeria’s National Commission for Museums and Monuments, included concerns that returned artefacts would not be properly managed.

So, Nigerians formed an independent body in 2020 – the Legacy Restoration Trust – to act as an intermediary and manage negotiations with foreign museums. Tijani believes it was the best step forward and is designed to survive changes in Nigerian politics.

Nigeria has since been proactively clinching agreements for returns with institutions in the United States, Germany, Ireland and Britain, including the University of Aberdeen, the Church of England, the Fowler Museum in Los Angeles, the National Museum of Ireland and Berlin’s Ethnologisches Museum.

As we spoke, Tijani was in the middle of finalising the return of three Nigerian artefacts from the Metropolitan Museum of Art in New York, announced in June – two 16th century Benin Bronze plaques and a 14th century Ife head. He hoped that more museums with similarly stolen Nigerian objects would consider returning them.

But negotiations with the British Museum have often reached an impasse. Britain’s government recently adopted a “retain and explain” stance for state-owned institutions, meaning that monuments and contested objects will be kept but contextualised. European state-owned institutions require new laws to be able to return their collections. This has been enacted in France and Germany but British institutions are still prevented from doing so by the British Museum Act of 1963 and the National Heritage Act of 1983. The UK government has said it has no plans to amend those laws to enable return.

The Benin Dialogue Group, a network of Nigerian representatives and European museums including the British Museum, have been engaged in decades-long discussions about loaned returns with few tangible timelines. “We thought that this is the group that will enable the United Kingdom to succumb to the issue of repatriation,” says Tijani, but “this process is not very clear.”

He says Nigeria “will not relent”, and hopes to “talk more with the British Museum and then come up with a very concise, concrete, timely repatriation of our objects.”

The British Museum told Al Jazeera it was “engaged in a series of dialogues with different parties in Benin, especially the Legacy Restoration Trust, and is aware of widespread hopes of future cooperation.” It would not offer any clarification on a date for loaned returns.

Chapter Two: Slavers turned merchants

Having been the largest enslaver nation – enslaving about 3.1 million African men, women and children during its participation in the trade – Britain enacted laws in 1807, with further acts in 1811 and 1833, that abolished the trade after frequent rebellions by enslaved people eventually prompted concerns from influential members of British society about their appalling treatment.

Abolitionist Ignatius Sancho – born on a slave ship travelling from Guinea – was enslaved in the Spanish West Indies. He was sold again at just two years old and forced to work in London as a house slave until adulthood. Sancho ran away aged 20, learned to read and became the first Black Briton to vote in an election. The letters he published in 1782 about his life as an enslaved person influenced British foreign secretary Charles James Fox and set the course for abolition. Fox proposed the anti-slavery bill that was passed into law.

Yet, slavery was a source of immense wealth for Britain, and fuelled industries such as shipbuilding, banking, and insurance. In need of replacement sources of wealth, politicians developed the idea of “legitimate commerce”, whereby African forced labour in African countries would produce resources shipped to enrich Britain.

For this to happen, Britain’s military officers negotiated so-called treaties with African rulers that would establish British trading, and lead to Britain declaring itself the legitimate ruler. Kings of Africa’s mega kingdoms – some of whom had acted as middlemen, selling their prisoners of war to Europeans – opposed these treaties. So Britain’s military – on a mission to “protect” Africa from slave traders – started to ally with local rulers who were favourable to British trade and to violently dispose of African kings who blocked these treaties or this trade. Stolen artefacts from the captured kingdoms paid Britain’s costs from these wars. The result was the destruction of Africa’s oldest empires.

The campaign against slavery also allowed it to brutally amass colonies and loot civilisations’ artefacts. This included wealth and treasures from kingdoms that are now part of modern-day Nigeria and Ghana.

Shipbuilder Macgregor Laird formed the African Inland Commercial Company in 1831. He had a great passion for “legitimate” trade in Nigeria as a substitute for slavery and estimated that one resident could be forced into harvesting a tonne of palm oil a year to supply Britain’s flourishing soap industry.

“An able-bodied slave is at present worth about four pounds’ worth of British goods, and when he is shipped he can produce nothing more. But supposing he was kept in his native country, he might [by] very slight exertion produce one ton of [palm] oil per annum, which would be worth eight pounds or purchase double the quantity of British goods,” wrote Laird and R A K Oldfield, a surgeon who travelled with him, in a book about their travels in West Africa in the 1830s.

Their expedition was led by British explorer Richard Lander who removed what is thought to be the first artefact taken from Nigeria during Britain’s process of colonisation. It was an intricately carved Yoruba stool that is ironically now named after Lander and held in the British Museum.

It is thought that Lander’s trip, funded by the British government, provided vital details on navigating Nigeria’s interior. According to Siollun’s book, while European exploration had been limited to the coast because almost all who went further died from illness, the arrival of quinine – a medicine used to treat malaria – changed this. Soon after, explorers, merchants and slave raiders ventured beyond Lagos’s coastlines into regions previously considered a “white man’s grave”.

Like other European powers, Britain rushed to control African land not just for palm oil but also gold, ivory, diamonds, cotton, rubber and coal. “Trade in produce has been gradually growing up and gaining upon the Slave Trade in proportion as the enterprise of the British merchant,” it was noted in Britain’s parliamentary papers in 1842. And by 1845 the British government abolished duties on palm oil observing that imports “had nearly quadrupled”.

Yet slave-raiding continued among some British merchants because of the enormous profits involved. This led to Britain more rigorously pushing “legitimate” means of trade, subsequently granting charters to companies to exploit trade across West Africa. The most successful was the Royal Niger Company (RNC) governed by merchant George Goldie between 1879 and 1900. Goldie was instrumental in colonising Nigeria and South Africa by establishing mineral companies in the region. He set up administrative posts manned by officers who used the same violence and intimidation carried over from the slave trade. Historian Felix K Ekechi argues in his book, Portrait of a Colonizer: H. M. Douglas in Colonial Nigeria, 1897-1920, that “colonial officials, and particularly the earlier administrators were not only imperious, overbearing but consciously callous and brutal towards Africans”.

Britain used discriminatory policies to protect its merchants from local competition. It enacted high tariffs on indigenous palm oil trade and confiscated the goods of anyone not paying its fees. African merchants found themselves unable to grow their own economies. This prompted hostile opposition from locals, according to papers of the RNC, held at the University of Oxford’s Bodleian library. Farms and entire villages were burned to the ground and villagers beaten to crack down on growing opposition. “To the natives, it appeared as if Britain had abolished indigenous slavery so it could replace it with its own system of slave labour,” historian Siollun says of the company.

The tariffs RNC imposed made it extremely lucrative. According to parliamentary papers, it earned shareholders a six percent profit annually.

After the Berlin Conference of 1884 endorsed European claims to African territories, Goldie led punitive expeditions against the Nigerian kingdoms of Nupe and Ilorin in 1897, removing their rulers for opposition towards its military outposts in the region. RNC subsequently controlled swaths of territory covering a population of more than 30 million people.

In 1899, Henry Labouchère, the MP for Middlesex, described the process by which territory was acquired during a parliamentary meeting. “Someone belonging to one company or another meets a black man. Of course, he has an interpreter with him. He asks the black man if he is proprietor of certain land, and if he will sign a paper he shall have a bottle of gin. The black man at once accepts; a paper is put before him, and he is told to make his mark on it, which he does. And then we say that we have made a treaty by which all the rights in that country of the emperor, king, or chief, or whatever you call him, have been given over to us. That is the origin of all these treaties.”

In one instance, RNC was supposed to pay the Sokoto empire in northern Nigeria £300 to £400 annually in mining rights and for the empire to recognise Britain as “the paramount power”. Officers knew the true value was £1,000 a year, about £132,000 in today’s figures. But nothing was paid, and Sokoto was later violently conquered.

In southern Nigeria, the Igbo communities in the Delta state formed an organised resistance to the company known as the Ekumeku movement, meaning “the silent ones”. The continuing uprisings and fear that Germany or France might take control of the area prompted Britain to buy out RNC’s territories. Military expeditions to defeat the Ekumeku continued until the mid-1900s with officers during those wars acquiring Igbo artefacts that ended up in London.

In 1929, RNC’s subsidiary was absorbed into Unilever, which was owned by William Lever and extracted palm oil in Gambia, Ghana and Nigeria to use as a key ingredient in its soaps. Unilever holds a number of African artefacts but says these were gifts given to its employees.

However, more artefacts would be seized during wars between Britain and various local kings who were dethroned and replaced with corrupt “puppet” rulers. Britain’s National Archives referred to it as “indirect government” in the region. This involved using local chiefs to implement colonial policies. Britain would be in charge but traditional authorities would have the appearance of power.

In 1892, British soldiers attacked the Yoruba kingdom of Ijebu using early machine guns known as maxims. The kingdom’s artefacts were looted as punishment for blocking trade.

Ijebu’s king controlled routes leading to the costal ports of Lagos. Captain George Denton, acting governor of Lagos, had visited the capital Ijebu-Ode in 1891 to gain access to trade for British companies. But the Ijebu king refused and British officers threatened the use of force if they did not sign a treaty. When the Ijebu king and his chiefs objected that they could not read English, British officials had it signed for them by Ijebu people living elsewhere. This fuelled further hostility and when the Ijebu would not allow a British officer passage through their territory, a punitive expedition was mounted for allegedly breaching the terms of the signed treaty, according to parliamentary records.

Historical accounts estimate more than a thousand Ijebu soldiers were killed. “On the West Coast, in the ‘Jebu’ war, undertaken by Government, I have been told that ‘several thousands’ were mowed down by the Maxim,” Frederick Lugard, later governor-general of Nigeria, recalled in his 1893 book, The Rise of Our East African Empire.

Having captured most of the Yoruba kingdoms by 1895 including Ibadan, Oyo and Abeokuta, British forces moved inwards toward the ancient kingdom of the Bini people – the Benin Empire.

In February 1897, Britain launched another “punitive expedition” using 1,200 naval soldiers and 5,000 colonial troops. The massacre lasted 10 days and Benin was burned to the ground. It was in response to the Benin king’s men killing seven officials from a British convoy, including its leader Captain James Phillips, which had demanded control over the palm oil and rubber trade.

At the time, Benin kingdom, modern-day Edo state in southern Nigeria, had been a self-sustaining nation surrounded by former civilisations crumbling under a siege of European invasion.

Benin city, formed around the 12th century, was one of the first places in the world to have street lighting, according to Siollun’s research. The 120-feet-wide roads to the oba’s palace were lit at night by metal street lamps – fuelled by palm oil – that stood several feet high. Its earthwork walls were described by archaeologists as the world’s largest before the mechanical age.

It was a prosperous trader in enslaved people – largely its war captives. The official rhetoric, according to documents from colonial records, was that soldiers saved Bini people from a haven of “slavery” and “barbarism”. British accounts suggest Benin was heavily engaged in human sacrifices naming it the “city of blood”. According to parliamentary records, soldiers came across “several deep holes in compounds filled with corpses”.

But Nigerian narratives say some of those dead had been hurriedly buried by villagers before fleeing the besieged city. One possible explanation is that British soldiers “had been firing long-range artillery, rockets, machine guns, for hours and days even before they entered Benin,” Siollun tells Al Jazeera, “so it is possible that a great number of corpses that they saw were the casualties of their own attacks.”

While eight British deaths were reported to the House of Parliament, Benin deaths were not counted. At least 3,000 artefacts were looted from the royal palace and surrounding homes – the true number is unknown. Burn marks from the blaze are still clearly visible on some looted artefacts. The bounty was auctioned off in London to private collectors and galleries across the West in what historians believe was a pre-planned loot.

Captain Phillips had written to Britain’s Foreign Office in November 1896 that, “I would add that I have reason to hope that sufficient ivory may be found in the king’s house to pay the expenses in removing the king from his stool,” according to correspondence papers held in Nigeria’s National Archives.

Benin’s capture was celebrated in American and British newspapers. British soldiers kept some of the loot for themselves. They dressed up in fake native wear and wore blackface to reconstruct their lucrative exploit.

The Benin Bronzes, a collection made up of carved ivory, bronze and brass crafted sculptures and plaques, are not mere artworks but catalogue the story of Benin – its achievements, explorations and belief systems.

They ended up in more than 160 museums globally. The largest collection – 928 – is at the British Museum where an exhibition took place within months of the kingdom being razed. Berlin’s Ethnological Museum holds 516 – the second largest collection. There are 173 at the Weltmuseum in Vienna, 160 at the Metropolitan Museum of Art (Met) in New York, 160 at Cambridge University’s Museum of Archaeology and Anthropology and 105 at Oxford University’s Pitt Rivers Museum.

“It was purely a colonial power exerting power on the community. They looted and burned down everything and carted away what they took off the people,” Tijani, of Nigeria’s National Commission for Museums and Monuments, tells Al Jazeera.

A spokeswoman for Austria’s Weltmuseum Wien acknowledges 13 of its 173 Benin Bronzes “have been linked definitively to the British invasion” though eight were acquired in the 16th century. “Further research will seek to establish the provenance of the rest of the objects,” she told Al Jazeera via email. “The museum itself is not authorised to decide to return objects. Such decisions are made by the government.”

Weltmuseum Wien has committed to loans via the Benin Dialogue Group and the sharing of digitised archives in the Digital Benin project, which will create an online database of more than 5,000 objects held globally in public institutions by 2022.

In a statement to Al Jazeera, the British Museum added that “the devastation and plunder wreaked upon Benin City during the British military expedition in 1897 is fully acknowledged by the Museum and the circumstances around the acquisition of Benin objects explained in gallery panels and on the Museum’s website”. In November 2020, the British Museum announced it would help in archaeological excavations of the royal palace’s ruins, before a new museum is built on the site.

The Benin Kingdom theft is well-documented. Yet Benin Bronzes remain profitable for their owners, with single pieces having fetched more than $4m at auction houses. “The nature of how these things were carried out is illegal, everybody understands that so therefore these objects need to come back to us,” Tijani says.

Chapter Three: Stolen skulls and gold

Throughout Britain’s anti-slavery missions, many prized African artefacts arrived in London to be sold onto European collectors and museums.

At the time, scholars doubted “primitive” Africans could create such works. German archaeologist Leo Frobenius, who was accused of having stolen a sacred Yoruba Ife head in 1910, argued they were of Greek origin and not African. “I was moved to silent melancholy at the thought that this assembly of degenerate and feeble-minded posterity should be the legitimate guardians of so much loveliness,” he wrote in his book, Voice of Africa, published in 1913.

Charles Read, a British Museum curator between 1880 and 1921, had a similar reaction to the Benin Bronzes. “We were at once astounded at such an unexpected find, and puzzled to account for so highly developed an art among a race so entirely barbarous as were the Bini,” he said. Read saw the museum “as a centrepiece of the British Empire”.

Ghanaian authorities have also tried to reclaim gold treasures looted by British soldiers from the Asante kingdom, which is also known as Ashanti.

In 1872, Britain expanded its West African territories by purchasing the Dutch Gold Coast. It had become less profitable to the Dutch after the abolition of the slave trade. But the Asante, described by British MP Charles Adderley as “the most warlike of the African tribes,” refused to acknowledge British rule and in February 1874, a “punitive expedition” was mounted using 2,500 British troops. The Kumasi royal palace was destroyed with explosives and the city was ransacked and burned.

“As the amount realized by the sale of loot, was inconsiderable, the troops and seamen received a gratuity of thirty days’ pay, in lieu of prize money,” according to the memoir of British forces commander Sir Garnet Wolseley, published in 1878.

Items stolen by British soldiers from the Kumasi royal palace were auctioned off at crown jeweller, Garrard, less than three months after Kumasi’s destruction. Garrard operates today in London’s West End.

Asante leaders were forced to sign a treaty in which they would renounce rights to their lands, end human sacrifice and pay Britain’s cost of the war through 50,000 ounces in gold, according to the Wolseley memoir. The treaty also made allocation for British commercial interests. When Asante leaders could not pay all the gold demanded, its new king Prempeh I petitioned the British to allow more time to pay the sum. The petition was rejected and Asante territory became part of Britain’s Empire in 1897 after a second punitive expedition between 1895 and 1896.

Ghanaian officials have been keeping an eye on the paced developments in Nigeria over the Benin Bronzes. “There is now a kind of organised structure [in Nigeria] that is advocating for the return,” explains Nana Oforiatta Ayim, founder of Accra based ANO Institute of Arts and Knowledge. “That’s what I’m trying to put in motion at the moment is that same organised push towards getting our objects back.”

She heads the President’s Committee on Museums and Monuments which will advise the government on restitution. She believes there has been a “silence” on looted Asante treasures with little public data. In May, the 13-person committee launched a report on next steps that will include compiling inventory of items held by museums globally.

Around 514 Asante royal regalia ended up at the British Museum, according to data from a Freedom of Information (FOI) request by Al Jazeera, 19 at the Victoria and Albert (V&A), and 14 at the Wallace Collection. Several other institutions hold Asante loot including New York’s Met, the Dallas Museum of Art, Glasgow Museums and the British royal family.

The Wallace Collection told Al Jazeera 12 of its items “are on display and can be seen for free on a visit to the museum.

“We have no active restitution or repatriation claims for any objects to be returned to their country, state, community or owner of origin,” it said via email.

The Met did not respond to a request for comment on its Ghanaian treasures. The British Museum repeated its ethos. “We believe the strength of the British Museum collection resides in its breadth and depth, allowing millions of visitors an understanding of the cultures of the world and how they interconnect over time – whether through trade, migration, conquest, or peaceful exchange,” the museum said in its statement to Al Jazeera.

The V&A bought 13 royal artefacts from the Garrard auction with additional buys from soldiers who participated in the looting. Just three items of its collection are on public display while 16 are held in storage, according to details from a freedom of information (FOI) request by Al Jazeera.

The V&A has only received one request for return from an African country, it says. Ethiopia’s former President Girma Wolde-Giorgis sent a letter in 2008 requesting the repatriation of artefacts looted by British troops in Maqdala in 1868. The museum responded a decade later with the offer to loan the objects back long-term. That offer was rejected.

In 1974 the Asante royal family asked the UK government to pass legislation that would allow the return of looted treasures. The reply was “very racist and rude,” recalls Oforiatta Ayim.

The case was referred to the House of Lords. In response to the suggestion that sacred Ghanaian objects embody the souls of ancestors, one Lords member said, according to parliamentary minutes, “would it not be possible to keep the booty and return the souls?”

Another Lords member cautioned treading “warily when it comes to returning booty which we have collected,” as that process could “turn into a strip-tease” of Britain’s museums.

Relations had not improved by the start of the millennium. In March 2000, Prince Edun Akenzua, of the royal court of Benin, also wrote to Britain’s Parliament demanding that a record of all looted artefacts be published.

“Britain, being the principal looters of the Benin Palace, should take full responsibility for retrieving the cultural property or the monetary compensation from all those to whom the British sold them,” he wrote.

Akenzua’s plea was largely ignored. Chao Tayiana Maina, co-founder of the Open Restitution Africa project and the Museum of British Colonialism in Kenya, adds that Britain’s policy on return is an added challenge. “What we are seeing with the Germans and the French is a bit more flexibility.

“The concept of loans is really a bandage over a broken bone,” says Maina. “When you have these objects on loan there is still this overarching cloud that they are still not ours.”

Kenya is demanding the return of more than 2,000 historical artefacts held in the UK. One particularly shocking case is that of the skull of Nandi chief Koitalel Arap Samoei. He fought against Britain’s railway project through his land and in 1905 was shot dead by British colonel Richard Meinertzhagen. Samoei’s body was decapitated and the head taken to London.

The skull is still held in Britain although the items he was wearing that were stolen by Meinertzhagen were returned by his son in 2006.

Empty shelves were recently showcased at the Nairobi National Museum to represent more than 32,000 objects taken out of Kenya during the colonial era. The exhibition, called Invisible Inventories, examined how such a profound loss of heritage affects communities.

In 1902, British colonial officials seized the Ngadji, a sacred drum of the Pokomo people of Kenya’s Tana River valley. The drum has been in the British Museum’s storage room for more than a century, never once put on public display. Maina points out that many contested collections have been in storage for centuries since being shipped to Western museums. Catalogue details have been inaccurate while objects have been left to gather toxic dust.

“Western museums act as if returning is the hardest part but we are the ones who have to do the hard job. We are the ones who have to receive objects that are sometimes poisonous because they have been stored in arsenic,” she says. “Restitution is a much broader process in terms of what happens even when the object comes back and how they are reintegrated into society.”

Egyptian writer Ahdaf Soueif resigned as a trustee of the British Museum in 2019 because of its position on repatriation. Soueif said her resignation was not because of a single issue but a cumulative response to the museum’s immovability on issues of critical concern to young and less-privileged people. “The British Museum, born and bred in empire and colonial practice, is coming under scrutiny. And yet it hardly speaks,” she wrote in a blog post. She asked, will the museum “continue to project the power of colonial gain and corporate indemnity?”

Oforiatta Ayim, who is an historian and curator, worked a short stint at the British Museum and recalls going into its storage. “Especially in the rooms where the African objects are. You feel this energy there and you think these objects don’t feel right here,” she says. “If you look at our knowledge systems and you look at how objects are seen and animated – they are not these graveyards of a mausoleum, there is a spirit and an aliveness to them.”

She quotes the V&A’s director Tristram Hunt writing that “empire was also a story of cosmopolitanism,” and suggests this amounts to a continued romanticism of imperial violence that ignores its ruinous effects on generations.

The argument at its base is a legal and moral one. “You kill my parents, and then take objects from me … when I come to you and say this has been a really traumatic event for me and I want those objects back you say to me, ‘well they are mine now maybe I’ll lend them to you’,” says Ayim.

Despite the offer, artefacts are not currently on loan to any African country by the V&A or the British Museum. The British Museum currently has seven Benin artefacts on loan to other museums in Europe, according to Al Jazeera’s Freedom of Information request. It has objects out on loan to the UK’s Wilberforce House Museum in Hull, London’s V&A, M Shed Museum of Bristol, and the House of European History in Brussels. Four objects associated with the Asante royal court are on loan to museums in the US, the names of those institutions were not released.

The V&A said it does not have any Asante objects out on loan anywhere globally.

Chapter Four: Legislating return

In the 1990s, the Washington Principles enacted guidelines around the return of Nazi-confiscated art. In 2002, the heirs of Dr Arthur Feldman sought the return of four old master drawings from the British Museum because they had been stolen by the Gestapo. The case went to court and the family lost on the grounds that British law forbids state museums returning their collection. It prompted a private members’ bill in parliament by MP Andrew Dismore which led to the Holocaust (Return of Cultural Objects) Act 2009 in the UK. “Sadly, there is nothing we can do to reverse those appalling losses, but we can at least keep open the hope of the return of lost treasures, when they are identified in our museums,” one parliamentarian said in 2019 when the act was revisited.

For Osori of OSIWA, it serves as a paradigmatic case for legislation on returning African objects looted during colonialism. “You ask yourself why the restitution was able to take place in a much shorter time and it is still taking you this much time for you to do restitution for African cultural heritage.”

African leaders were delighted when French President Emmanuel Macron declared in 2017 that the return of African heritage to its ex-colonies would be a “top priority”.

“I cannot accept that a large part of cultural heritage from several African countries is in France,” he told students during a two-hour speech in Burkina Faso’s capital Ouagadougou. “African heritage cannot be a prisoner of European museums,” Macron later tweeted during his trip.

A 2018 report that he commissioned, by academics Bénédicte Savoy and Felwine Sarr, recommended African artefacts be returned. Around 90 to 95 percent of African cultural heritage is held overseas, the report found.

The French parliament subsequently passed a bill in December 2020 to allow African objects to be returned. “This is not an act of repentance or reparation,” minister delegate for foreign trade Franck Riester said.

Cambridge University’s Jesus College became one of the first British institutions to announce the planned return of a looted Benin Bronze cockerel. The college’s Legacy of Slavery Working Party, a group established to look at the institution’s connections to the slave trade, recommended it be returned.

But it was not until the death of George Floyd in the US and the Black Lives Matter (BLM) movement, that African repatriation gained global momentum. Restitution became part of a broader debate on racial equality in the wake of BLM protests in June 2020.

It was against this backdrop that in April, Germany became the first national government to say it would return a “substantive” number of more than 1,000 Benin Bronzes held by German institutions by 2022. It also committed more than $2m into provenance research of looted objects and guidelines towards return.

“We are facing the historical and moral responsibility to bring Germany’s colonial past to light and to come to terms with it,” Monika Grütters, Germany’s culture minister, said. “We would like to contribute to understanding and reconciliation with the descendants of people who were robbed of their cultural treasures during the colonial era.”

Returned bronzes will be displayed in a new museum called the Edo Museum of West African Art to be constructed at the site of the old royal palace in Benin City. The project designed by architect David Adjaye is due to open in 2026, although the dates have shifted multiple times.

Lagos state governors will loan from the British Museum the Lander Stool to display at a new centre due to open in spring 2022 – the John K Randle Centre for Yoruba History and Culture. The planned rooms of the building will tell the Yoruba story of human creation through its gods and goddesses, as well as the history of colonialism and the Transatlantic slave trade.

Lagos authorities say the centre will be a place where the Yoruba can “reclaim their heritage from a colonial narrative”. The British Museum will lend key objects on a long-term basis, it announced last month.

Chapter Five: African voices

The debate about who should be the custodians of African art has recently centralised in the Global North with academics and “experts” writing books on the Benin Bronzes to a plethora of rave reviews. It raises an uncomfortable truth that while they are vital to global discussions, Africans who are taking practical steps towards restitution have been drowned out by predominantly white male voices, Ayim says candidly.

“You are essentially doing what colonisers have been doing for centuries which is talking on behalf of someone and saying this is what should happen,” she adds.

The Pitt Rivers Museum has not repatriated its looted African items, despite being the hosts of several programmes focussed on restitution. When asked whether Pitt has returned any Benin Bronzes, the museum told Al Jazeera “no”.

In reality, restitution has been all talk without action. Azu Nwagbogu, founder and director of the LagosPhoto Festival and the African Artists’ Foundation, says institutions have “idolised themselves”.

“Restitution has become commodified, just like everything else that relates to Africa and its diaspora, it becomes something for intellectuals in Western institutions to go from conference to conference.”

African curators are calling for more meaningful discussions with the continent’s young generation. LagosPhoto, Nigeria’s biggest international arts festival, sought to make the conversation more inclusive last year. Its Home Museum project asked citizens to submit images of objects of personal significance under the theme Rapid Response Restitution.

The interactive online exhibition contains more than 200 submissions of personal ephemera and family heirlooms that each tell a unique story. It was about shifting dialogue about the legacies of loss from diplomats and intellectuals to citizens, says Nwagbogu. For him, photography has the power “not just to illustrate or tell a story but it also captures memory, ideas and history”.

Another project of his called Generator is in collaboration with Clémentine Deliss, who was a director of the Weltkulturen Museum in Frankfurt. It aims to develop local cultural custodians through access to arts education and research. “When these museums in Africa become physically realised we’re not looking to hire curators from elsewhere,” he says, “we want to be able to have people on the ground that are interested and skilled.”

That grassroots approach is snowballing. In Ghana Ayim has created the mobile museum, that travels across Ghana. She describes it as “a listening tool” with communities giving feedback on what they want from a future museum. This will eventually feed Ghana’s national strategy to create a museum model that is less “monolithic”.

Plans to build a $30m Pan African Heritage World Museum by 2023 are taking shape in Ghana. Kojo Yankah, a former member of the Ghanaian parliament who is behind the project, said it aims to inspire citizens “to know that there is something to be proud of in being African”.

Maina’s small organisation holds workshops retelling Kenyan history and offering up spaces for people to explore its impact. “It’s easy to think that nothing is happening in terms of restitution or that very little is happening,” says Maina, “but so many people are involved. It’s just that they don’t have a platform.”

Across the continent, African voices on return are getting louder. The African Union (AU) announced plans to build a $57m Great Museum of Africa by 2023 in the North African country of Algeria.

Although some have questioned this specific location, Angela Martins, head of culture division at the AU, tells Al Jazeera the site in the country’s capital Algiers was offered by the Algerian government and would promote continent-wide cultural heritage.

To Martins, colonial powers recognising that assets were looted and not simply “taken” is the first major hurdle. She would like to see reparations given for stolen assets. The Great Museum of Africa would be “a dedicated institution which will be negotiating the return of illicitly trafficked heritage,” Martins continues.

It would “initiate negotiations with member states and the countries that are having looted or illicitly trafficked objects. So that they can come to an agreement.”

A planned AU Model Law report equally aims to align approaches on restitution for member states. “Our main role is at the policy level,” says Martins, who believes its report would be the “major instrument” on the subject of restitution.

Tijani says Nigeria will not stop seeking the return of its cultural artefacts. The objects recovered so far are few in comparison to the amount looted. Far more are suspected to be in private European homes. Nigeria is seeking back illegally exported treasures from the Nok era, the Igbo people, Oku and Eloyi. The latter unsuccessfully revolted against British rule in 1918.

Britain’s Queen received a Benin bronze head as a gift by Nigerian general Yakubu Gowon during a state visit in the 1970s. The head had been looted from Nigeria’s national museum in Lagos after it had been purchased back from Britain in the 1950s. Nigeria concedes its museums were “porous”. “There are situations where even the museum staff are capable of colluding with other people to loot some of our objects away just for them to get some monetary value,” says Tijani, but he insists more stringent authorisation systems have been put in place to reduce thefts.

Nigerian federal authorities want to collaborate with countries to block objects being transported abroad without a permit, he explains. “The customs or the authorities of those countries must take possession of these artefacts and notify us.”

In April, Nigeria received back a stolen Yoruba Ile-Ife head recognised at an airport in Mexico. While the University of Aberdeen has agreed to return a Benin Bronze head acquired in an “extremely immoral” way, there is a second in its possession that Nigeria wants back.

“We are discussing with them because they want to confirm if it is part of the loot of 1897,” says Tijani. Private European holders, however, have asked for monetary compensation for the return of looted Bronzes, he explains.

While Nigeria has previously purchased back Benin Bronzes, that era appears to be over. “It is not morally right for us to pay for our own objects,” says Tijani. “We are not ready to pay for any compensation.”

Nigeria’s organised position on restitution has not been without controversy.  The current Oba of Benin, Ewuare II, said in a statement to media that anyone working with the Legacy Restoration Trust is “an enemy,” and returned objects should come to him. Tijani says he does not want a situation where overseas institutions “start thinking twice,” on repatriation. “We are not taking these objects to other places. We agree we want to display these objects in Benin City. So let us be united,” he says.

As the debate intensifies, African countries are more affirmative in their pursuit. “It’s a big international issue now,” says Tijani. “Anywhere we come across these objects whether in private collections or in public institutions we are going to lay claim … that we are sure of.”