African conservation fraternity and governments are increasingly demanding for the return of cultural artefacts that were stolen during the colonial period by governments and individuals.
However, they are facing the challenge of insufficient global and local laws on repatriation as well as resistance from American and European museums, who claim that African museums lack the money and infrastructure to conserve the artefacts if they were to be returned.
The demands for restitution have been going on covertly, with most African governments preferring to take a bilateral negotiation approach.
Ethiopia negotiated for the return of its 1,700-year-old Obelisk, a religious granite post that was in 2005 returned after 68 years in Italy. It was looted by the troops of the Italian dictator Benito Mussolini.
But now more African museums and governments are openly demanding the return of the cultural objects that were carted away to the US and Europe and constitute some of the leading exhibitions in Western museums.
Most museums prefer to loan out the artefacts for a period of time but have strongly resisted repatriation.
Dr Purity Dasm, the director of Antiquities, Sites and Monuments at the National Museums of Kenya (NMK) said museums abroad have been silent on the issue of repatriation and most are advocating for loaning of the collections because they hold international collections and it would be a blow for them with mass repatriation.
"Most individual collectors have been donating or handing over their collections to museums. They know there are no laws which can force museums to return collections, and most of them have given conditions such as asking museums to make sure these collections go into permanent exhibitions," said Dasm.
Former NMK Director-General Prof George Abungu, who is also the founder of the International Standing Committee on Anti-Illicit Trafficking on Antiquities, said that some of the Western museums have branded themselves "universal museums" which means they represent everybody and nobody should question their ownership of artefacts.
"Cultural heritage is universal, but it is also unique to cultures and societies. When you take away cultural property, you take away the life and history of a people," said Prof Abungu.
He initiated the negotiation of the return of the Vigango of Kenya's Giriama that were recently returned to Kenya by the Denver Museum of Natural Science.
Prof Abungu said African museums must operate from the basis that those who appropriated African cultural artifacts have made them part of the American and European environment.
"There must be a detailed catalogue of how each of the items were appropriated. Those that were looted without the consent of the owners must be returned," said Prof Abungu.
For decades, Africans have advocated for the return of this heritage—art and ceremonial objects, human remains, natural history specimens, archives and intangible cultural heritage like sound recordings and photographs.
Lack of legal muscle
There are hundreds of thousands of African cultural artefacts held by museums and collectors globally.
While most African countries are yet to put in place laws to address the issue of repatriation, international conventions such Unesco's 1970 Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transport of Ownership of Cultural Property, only applies to the post-1970 period.