Case study

The Duke of Sutherland’s disposal of Titian’s Diana and Actaeon

Posted by : Mike Chantler

Farrer’s achievement lay in their blend of legal expertise and a quite exceptional broader perspective.


Farrer & Co acted for the Duke of Sutherland on the UK’s biggest ever sale of art in private hands to the nation. This case, which received extensive national press and TV coverage, involved the disposal of the Duke of Sutherland’s painting Diana and Actaeon by Titian, completed in January 2009.

The £50million deal with the National Gallery in London and the National Galleries in Scotland was the largest ever of its kind and followed confidential negotiations dating back to March 2007.

The two galleries have also been granted an option, exercisable at any time until the end of 2012, to acquire Titian’s Diana and Callisto for a similar amount.

The Titians, described by Lucien Freud as “simply the most beautiful pictures in the world,” have been regarded as two of the most important paintings in private hands in the UK. The sheer scale and complexity of this sale to the nation, at such a high level, involved our private client experts, with further support from the firm’s IP & Commercial, Banking and Media teams.

“What really impressed me was their sensitivity and understanding of the broader issues,” said Terence Fane-Saunders, Adviser to the Duke of Sutherland and Chairman and Chief Executive of Chelgate. “They recognised that it was not enough to deliver legal solutions if those solutions took no account of other sensitive and complex issues surrounding this negotiation. Their achievement lay in their blend of legal expertise and a quite exceptional broader perspective.”