Written by: Miloš Stevanović

A photograph of Pablo Picasso’s painting Femme dans un rocking-chair (Jacqueline), shown at an auction in London. The painting has become the subject of an international legal drama after its buyers – venture capitalists led by collector Sasan Ghandehari – filed a lawsuit against the prestigious auction house Christie’s. They claim that Christie’s misled them by concealing the provenance (ownership history) of the artwork: it turned out that the previous owner of this Picasso piece was a convicted drug trafficker, which was not disclosed at the time of sale. The lawsuit, filed in London in mid-2025, has raised questions about professional standards and due diligence processes in the art trade, as well as the impact of “dirty” provenance on the value of an artwork.

Key Facts of the Case

Time and Place: The lawsuit was filed on July 21, 2025, before the High Court of England (Chancery Division). At the center is the painting Femme dans un rocking-chair (Jacqueline) from 1956, by Pablo Picasso. Christie’s offered the work at an evening auction in London in late February 2023.

The Purchase Arrangement: The plaintiff is Brewer Management Corporation (BMC) from the Virgin Islands, which, through its representative, venture capitalist and collector Sasan Ghandehari, participated in the auction as a third-party guarantor. Under an irrevocable bid agreement, BMC/Ghandehari guaranteed a bid of £14.5 million for Picasso’s painting – committing to purchase it if no other buyer emerged. When no higher bid than the reserve price appeared, BMC took over the painting and paid an initial amount of about £4.8 million to Christie’s (in accordance with the contract, likely including commissions and guarantor credits). Christie’s continued to claim the remainder up to the full £14.5 million, while BMC intended to resell the painting to another interested buyer at a profit.

The Painting’s Troubled Past: A few months after the auction (May 2023), Ghandehari investigated the painting’s provenance and discovered an alarming fact – the previous owner, Spanish businessman José Mestre Fernández, had been convicted of international cocaine trafficking. Mestre was arrested in Barcelona in 2010 (202 kg of cocaine seized in the port) and sentenced in 2014 to several years in prison. According to available data, it was Mestre (or his family) who consigned the painting to auction, while Christie’s allegedly presented to buyers that the work was being sold because the previous owner had “died” and that it was being sold by his son heir. In reality, Mestre was apparently still alive at the time of the sale, and his criminal past and the possible connection of the painting with drug money were not disclosed to the buyers.

Buyers’ Reaction: Believing that knowledge of such provenance would have changed their decision to buy, BMC and Ghandehari filed a lawsuit seeking annulment of the contract and refund of the paid amount. They argue that withholding the identity and reputation of the previous owner constituted a material misrepresentation – a key fact affecting the value and legality of the artwork. They claim that once its criminal provenance became known, the painting was no longer marketable (“unsellable on the market”) or only saleable with a significant discount.

Parties to the Dispute: The plaintiff is Brewer Management Corp., an investment firm acting on behalf of venture capitalist Ghandehari, while the defendant is Christie’s, one of the world’s largest auction houses. Ghandehari is a prominent collector and investor (linked to the HP Trust fund), with his wife active in art institutions – highlighting that the plaintiffs are experienced actors in the art market. On Christie’s side, the consignor (seller) of the artwork, indirectly involved, is the family of José Mestre.

Legal Basis: Plaintiff’s Claims and Christie’s Defense

Plaintiff’s Claims: BMC argues that Christie’s breached its obligations to the buyer by failing to disclose material information about the provenance of the work. The lawsuit alleges that the auction house made false representations about the ownership and history of the painting, thereby “positively misleading” the buyer and concealing serious concerns regarding the piece – including the possibility that it was actually the product of crime, purchased with drug-trafficking money. Such misrepresentation, according to the plaintiff, provides grounds for rescission of the purchase agreement due to material error or fraud. BMC emphasizes that it would never have agreed to guarantee the purchase had it known the true ownership history of the painting. In a press statement, BMC’s representative pointed out that this case raises broader questions of conflicts of interest and professional standards in the high-value art trade – suggesting that Christie’s may have placed its commercial interests above its duties to the collector client. In other words, the accusation implies a breach of trust: that the auction house, in order to secure a sale, withheld circumstances critical to the legal and reputational status of the artwork.

Christie’s Defense: The auction house denies these allegations and announced a vigorous defense in court. In a media response, a Christie’s spokesperson framed the case as a “simple debt claim,” stressing that Christie’s will steadfastly defend its reputation and contractual positions. From the auction house’s perspective, BMC undertook the obligation to purchase and owes the agreed amount, so the lawsuit is seen as an attempt to avoid paying the agreed price due to “buyer’s remorse.” Christie’s key argument is that it fulfilled all its legal and regulatory obligations regarding the vetting of the work and the consignor. Citing client confidentiality, Christie’s emphasizes that auction houses are obliged to protect the identity and information of their sellers and buyers, but that this does not mean they violated the law – assuring that the necessary due diligence was conducted in this case and that nothing unlawful or improper was done. Christie’s may argue that the mere fact the previous owner was convicted does not necessarily invalidate the sale, unless it could be proven that the painting was the direct product of crime (purchased directly with illicit funds) or subject to seizure. They might also argue that there was no positive duty to disclose the seller’s reputation to the client, especially given contractual confidentiality and the common practice in the market that consignors often remain anonymous. Furthermore, Christie’s will likely argue that the plaintiff, as an experienced collector, bears some responsibility for conducting their own checks (principle of caveat emptor – “let the buyer beware”), and that there were no false statements but at most an omission, which does not invalidate the contract, especially if the auction house did not know of the criminal provenance or did not deem it relevant.

Legal Standards and Due Diligence in the Art Trade

The trade in artworks faces special legal risks related to provenance, ownership, and the legality of the artwork. For this reason, international and national frameworks have established due diligence standards to prevent auction houses and dealers from being intermediaries in the sale of stolen or unlawfully acquired works, or from facilitating money laundering through art. Key norms and practices include:

Obligation to Verify Client Identity (KYC): Under EU regulations (5th Anti-Money Laundering Directive, implemented in 2020), “art market” intermediaries – including auction houses – are required to identify and verify their clients (buyers and sellers) for any art transaction above €10,000. In the UK, these provisions were transposed into national law, meaning that Christie’s must know who the ultimate beneficial owner of the artwork being sold is, and who the buyers are, and check whether they are on sanctions lists or involved in criminal activities.

Verification of Provenance and Title of the Work: The standard of professional care requires that an auction house investigate the provenance of the artwork – its ownership history – to determine whether there is a risk that the work is stolen, illegally exported, or linked to crime. Many contracts with consignors include representations (warranties) that the seller has clear title to the work and that it is not subject to dispute. However, in practice, sellers may remain anonymous in catalogs, so buyers often rely on the reputation of the auction house and its background checks. Auction houses usually consult stolen art registries (such as Interpol’s database) and monitor media reports to detect red flags. In this case, publicly available information (an internet search) revealed the connection of the painting to a convicted criminal, raising the question of whether Christie’s should have discovered and disclosed this before the sale.

Compliance with Anti-Money Laundering Laws and Reporting of Suspicious Transactions: Under the UK Proceeds of Crime Act 2002 (POCA) and related regulations, art market intermediaries are obliged not to facilitate transactions involving illicit funds. In practice, if an auction house suspects that money used for the sale or purchase of art is connected to crime, it must file a suspicious activity report with the competent authorities (in the UK, the National Crime Agency – NCA) and may freeze or withdraw from the transaction. On the one hand, houses rely on principles of confidentiality and do not easily disclose the identity of sellers; on the other hand, regulations require them to “know their client” and take risk-based measures not to unwittingly enable money laundering. Balancing these obligations is a delicate part of the due diligence process – the recommendation is that intermediaries, if suspicious, rather withdraw from cooperation than risk legal liability.

Industry Standards and Ethical Codes: In addition to legal norms, there are voluntary standards and guidelines in the art industry. International organizations and dealer associations (e.g., BAMF in Britain, CINOA globally) recommend transparency and diligence in provenance checks. High-profile auction houses like Christie’s and Sotheby’s have provenance research departments and compliance specialists. Contracts with buyers typically disclaim responsibility for certain matters (e.g., authenticity is guaranteed to some extent, while ownership history is usually represented only to the best of their knowledge). Still, cases like this highlight that reputational damage and legal risk can be enormous if due diligence proves insufficient. In the words of Christie’s spokesperson, the house is “confident it fulfilled all legal and regulatory obligations regarding the vetting of the work and the consignor,” implying it will seek to prove it did everything reasonably expected under the circumstances.

The Impact of Criminal Provenance on the Value of Artwork

The ownership history (provenance) of an artwork can drastically affect its market appeal and price. Positive provenance – e.g., origin from a renowned collection or exhibition at prestigious shows – usually increases value. Negative or controversial provenance, by contrast, can damage a work’s reputation, make it harder to sell, or lower its price. If the previous owner was a notorious criminal, collectors and institutions may hesitate to buy such a piece due to stigma and legal uncertainty. In this case, the plaintiff claims that knowledge of the criminal provenance made the painting practically unsellable or only marketable at a significant discount.

Legal Risk: If there is an indication that the artwork was acquired with funds obtained through crime (e.g., drug money), authorities could theoretically attempt to seize it as proceeds of crime. Although it is unclear whether Spanish authorities are claiming this painting, the mere possibility of legal dispute over ownership deters potential buyers. No one wants to pay millions for a work that could be confiscated or tied up in litigation.

Reputational and Ethical Aspect: Major museums, auctioneers, and serious collectors avoid works with a “dirty” pedigree to protect their reputations. Buying art known to have belonged to a drug lord can be seen as undermining ethical standards or even indirectly glamorizing crime – something most reputable buyers wish to avoid. An artwork tainted by such a story can lose its aura of cultural value and become known primarily for scandal rather than artistic merit.

Reduced Demand and Value: For the above reasons, the pool of potential buyers shrinks, driving prices down. If someone agrees to buy, they will likely demand a substantial discount to offset risk and stigma. In the art world, works tied to controversies (e.g., previously stolen works or art entangled in restitution disputes) often fetch lower prices until their status is resolved or until negative publicity fades. In this case, Ghandehari claims he would have to sell the Picasso well below expected value due to the “shadow” of criminal capital hanging over it.

It is worth noting that “criminal provenance” does not always reduce value: sometimes notoriety attracts attention (there is a market for gangster memorabilia, etc.), but that generally applies to pop-culture objects or historical relics. In the high-end fine art segment, buyers value clear provenance and legal certainty more. Therefore, the court’s ruling will be important – if BMC succeeds in rescinding the purchase, it will signal that concealing problematic provenance will not be tolerated and that such works may need to be excluded from the market until their status is clarified.

The Importance of Picasso’s Femme dans un rocking-chair and Its Market Value

Femme dans un rocking-chair (Jacqueline) holds a prominent place in Picasso’s later oeuvre. The painting depicts Jacqueline Roque, the artist’s second wife and last great muse, seated in a rocking chair. It was painted in 1956 and belongs to what art historian John Richardson called Picasso’s “Jacqueline period” – the phase from 1954 until his death in 1973, during which Jacqueline’s figure dominated his work. The importance of this painting is evidenced by its inclusion in the retrospective Picasso: 75th Anniversary at New York’s Museum of Modern Art in 1957, meaning the artist himself considered it significant enough for his jubilee exhibition.

The market value of this painting is very high, as confirmed by the 2023 auction result. Christie’s offered the work with an expected range of around £15–20 million ($18–24 million), and at the auction on February 28, 2023, the painting sold for £16.89 million (about $20 million). That sum made it the top lot of the evening and one of the stronger results for Picasso’s works from the 1950s. For comparison, some Picasso paintings from earlier periods (e.g., Les Femmes d’Alger from 1955 or his Blue Period works) have fetched records of over $100 million, while portraits of Jacqueline from later years typically achieve tens of millions of dollars, depending on quality and size. Femme dans un rocking-chair is a large canvas (~194 x 130 cm) in oil, which adds to its value. Its 2023 auction coincided with the 50th anniversary of Picasso’s death, which Christie’s highlighted in its marketing.

Artistically, the painting is an example of Picasso’s late style – cubistically deformed female figure with emphasized curves and bold colors, reflecting his intimate fascination with Jacqueline. For collectors, special significance also lies in its provenance: it had previously been part of a collection that acquired it at a 2007 auction (indicating transparent ownership up to the 21st century), and it has been reproduced in literature and exhibited, all of which inspire confidence in its authenticity and importance. That is why the revelation that one of its owners was a convicted drug trafficker resonated so strongly in the art world – from the perspective of art history, the painting is unquestionably valuable, but the question arose whether that “stain in provenance” could overshadow its artistic value on the market.

Conclusion

The lawsuit against Christie’s concerning Femme dans un rocking-chair highlights the importance of thorough provenance checks and transparency in the auction business. For clients and collectors, the lesson is that even prestigious institutions may overlook (or withhold) critical information affecting the value and legal status of a work. From a legal standpoint, the outcome of this dispute will depend on proving whether a legally relevant misrepresentation occurred – whether Christie’s had an obligation and failed to disclose the criminal provenance of the painting, and whether that provides grounds for rescission of the sale. Regardless of the court’s verdict, the case will raise awareness in the art community of how essential due diligence is, and how fragile the reputation of an artwork can be when the world of crime intrudes into its story.

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