August 28, 2025
Harlingdon and Leinster Enterprises Ltd v Christopher Hull Fine Art Ltd [1989] EWCA Civ 4 (15 December 1989)
An art dealer sold a painting attributed to Gabriele Münter to another dealer for £6,000, but it was later discovered to be a forgery. The buyer claimed breach of the implied condition under s.13(1) of the Sale of Goods Act 1979 (sale by description). The Court of Appeal held there was no sale by description as the buyer had not relied on the seller's attribution but on his own judgment. Facts The defendant company, Christopher Hull Fine Art Ltd, through Mr Hull, offered to sell two oil paintings described in an auction catalogue as works by Gabriele Münter (1877-1962), a


