Can a painting attributed to Gustave Courbet be declared authentic by a legal expert and nevertheless be the subject of a request for cancellation of its sale for lack of authenticity? This is the paradox of a dispute which has opposed the purchaser of Two deer resting in a snowy landscape to its seller and to the professionals who participated in the transaction.
Presented as coming from the collection of art critic Théodore Duret (1838-1927), close to Courbet, this oil on canvas measuring 46.5 × 55.5 cm bears a stamp with the initials TD on the reverse as well as an FLD stamp on the stretcher, attributed with reservation
to the auctioneer Fernand Lair-Dubreuil. Its provenance is, however, debated.
In 2019, Johann Naldi, a Parisian gallery owner who became the owner of the work, lent the painting to the Courbet Museum in Ornans for the exhibition “Courbet / Hodler: a meeting”, organized from October 2019 to January 2020. The work is reproduced in the catalog under the attribution to Courbet.
On March 20, 2022, the painting offered at auction at Osenat, in Fontainebleau, sold for 156,250 euros, including fees. Thomas Morin-Williams acts as an expert for the auction house.
The Courbet Committee refuses the attribution
In April 2023, the buyer submitted the painting to the Courbet Committee, in charge of the painter’s catalog raisonné. The following July 2, he refused its attribution and its integration into the future catalog. The buyer then initiates legal proceedings aimed at obtaining the cancellation of the sale, involving the seller, the Osenat house and its expert.
As part of the procedure, Gilles Perrault is appointed as a legal expert in order to carry out a contradictory expertise. Initially reserved on the attribution, he modifies his assessment in the light of new documentary, material and stylistic elements produced in particular by the seller.
His report compares the painting to two works by Courbet preserved in the public collections of Troyes and Warsaw. Scientific analyzes also show that the pigments used are compatible with a creation in the second half of the 19th century, without this compatibility alone being enough to identify the author. On September 10, 2026, maCommune.info
reveals the conclusions favorable to authenticity formulated by Gilles Perrault. Johann Naldi uses this to question the methods of the Courbet Committee, which he criticizes in particular for the lack of motivation for its opinions and the anonymity of its five members.
A report contested by the buyer
But the expertise is far from putting an end to the dispute. In her right of reply of October 6, the buyer’s lawyer emphasizes that Gilles Perrault significantly modified his conclusions between his preliminary report and his final report. Several stylistic features, initially deemed “discordant” with Courbet’s work, would ultimately be described as “atypical.” She also criticizes him for not having personally examined the two comparison tables and for not having consulted the Courbet Committee.
The lawyer also disputes the scope of the research into Duret provenance. During this 1931 sale, the auctioneer walked away, considering that all the paintings were suspected of being fakes. The signatures were then erased from all the paintings. Journalists have argued that after all, authentic works could possibly appear in the lot, points out Gilles Perrault. The lawyer asserts that in any case, these articles do not make it possible to precisely identify those who would be concerned. This controversy is reminiscent of another involving Johann Naldi. A second painting belonging to him, Naked woman lying by the water
(1869), also presented in Ornans in 2019, was offered at auction by Rouillac in June 2023. It did not find a buyer, amid doubts expressed about its authenticity.
Addendum – October 15, 2026
Here is the text appearing in the catalog: “Oil on canvas, with the collection stamp ‘TD’ (Théodore Duret, on the reverse of the canvas) and the red wax stamp ‘FLD’ (on the stretcher; unidentified initials, probably Fernand Lair-Dubreuil).
