The art of restitution Pursuing justice through restitution committees for Nazi-looted art

Looted art has long been associated with war, but the Nazi regime elevated cultural plunder to an unprecedented scale, making it a central instrument in the persecution of Jews and other targeted groups. Early post-war restitution proved limited, and since the late 1990s new mechanisms were established in response to international calls for long-overdue justice.
This thesis examines the evolving approaches to Nazi-looted art restitution in Austria, the United Kingdom, and the Netherlands, focusing on the committees created to adjudicate such claims. It argues that a paradigm shift has occurred: from a strictly legal to a morally driven, victim-centred framework. These committees prioritize recognition of suffering and procedural justice, yet face the challenge of balancing legal certainty with morally just outcomes.
From an institutional perspective, the study shows that all three committees deliberately departed from traditional legal frameworks, favouring flexible procedures and accessibility. While initially praised, this informality exposed weaknesses such as lack of transparency, juridification, and dependence on the executive. Substantively, their approaches diverge: Austria remains rooted in legal doctrine, the UK embraces moral reasoning, and the Netherlands has developed a discretionary framework that increasingly acknowledges historical injustices and victim agency.
Engaging with scholarly debates, this thesis advocates a hybrid model that embeds moral reasoning within a legal framework. Sustainable legitimacy requires legal safeguards to ensure transparency, independence, and procedural clarity, while leaving space for moral considerations. Only such a hybrid paradigm can reconcile legal structure with recognition of historical injustice, strengthening victims’ agency and ensuring context-sensitive restitution.