Museums and universities around the world hold vast collections of cultural artefacts, artworks, objectified belongings and even ancestral remains. Many were not freely given but taken during colonial times, through force, manipulation, theft or violence. For decades, they have sat in storerooms and display cases, classified into categories like anthropology, natural history or ethnology, separated from the people and communities to whom they once belonged.
In recent years, there has been growing recognition that these collections carry painful legacies.
Calls for their return have become part of a global conversation about decolonisation, justice and healing. In 2018 French president Emmanuel Macron produced a report which called for a new ethics of humanity, setting off a new willingness to return African artworks and material culture. But African calls for restitution were made at least five decades earlier following former president of the Democratic Republic of the Congo Mobutu Sese Seko’s address to the UN.
In all these engagements, two words are often used: repatriation and restitution.
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At first glance they may seem to mean the same thing, and both involve the return of something. But as South African scholars, working in the fields of history, museum studies and human biology, we argue that the difference between these terms is not just semantic. The choice of word reflects deeper politics of justice, recognition and repair.
In our recent article we explained how we see this difference, and why the work of restitution restores people’s power over their future, and gives them a sense of agency. We argue that, for its part, repatriation has come to represent something less concerned with community restoration and has more to do with an administrative and logistical exercise.
We argue that, unlike repatriation, restitution speaks directly to justice.
Repatriation: the language of return
The word repatriation comes from the Latin patria, meaning “fatherland”. Traditionally, it refers to the return of a person or their remains to their country of origin. Governments often use this term for the logistical and legal transfer of people, artworks, or ancestral remains across national borders.
In countries that were settled by colonisers, like the US, Canada, Australia and New Zealand, repatriation has become the dominant language. This is partly due to specific laws and frameworks. In the US, for example, the Native American Graves Protection and Repatriation Act requires museums to return human remains and cultural items to Indigenous communities in a proactive manner.
In New Zealand, the national museum Te Papa plays a central role in repatriating Māori and Moriori ancestral remains from overseas institutions before returning them to local communities. In Australia, the choice of repatriation by activists, communities and scholars also sought strategically to draw a connection with the return of the remains of fallen soldiers.
In these contexts, repatriation is often framed as a process of giving back. States or museums take the lead, and communities receive.
Some Indigenous scholars and activists have challenged this framing, pointing out its patriarchal and statist overtones. They have introduced the concept of “rematriation”, signalling a return to “Mother Earth” rooted in Indigenous feminist perspectives, spirituality and community balance.
In South Africa, too, the term repatriation has been used, especially when the state arranged for the return of remains from abroad, as in the case of the return of Sarah Baartman from France.
Baartman was a 19th century Khoe (Indigenous South African) woman put on display in freak shows in Europe. Her body was later dissected by scientists within the realm of racial science and made to enter the systems of collecting and exhibition at the Musée de l’Homme in Paris. After being turned into an international symbol of the oppression of black women, Baartman also became a focus of claims for return made by Khoe and other activists and social movements in South Africa.
Repatriation has also been used for the return of the remains of ex-combatants and other patriots.
But unease began to grow. Was this language adequate for the deep work of justice and healing that communities were calling for? Or was it more concerned with national prestige than with community restoration?
Restitution: politics of justice beyond the transaction
Restitution is about returning something to its rightful owner, not simply as a transfer of property, but as an act of recognition, repair and healing.
Restitution is not just an event, like handing over an artefact in a ceremony. It is a process, time-consuming, emotional, and often painful. It involves research into how items were acquired, conversations with descendant communities, and decisions about how to care for or honour what has been returned. It recognises that the belongings taken were not just curiosities or objects, but were tied to community, and to language, ceremony and identity.
Read more: Looting of African heritage: a powerful new book explores the damage done by colonial theft
In many cases, ancestral remains were classified and objectified as human remains and specimens, stripping them of their humanity. Restitution, by contrast, restores them as ancestors with dignity and agency.
Restitutionary work: healing and reconnection
Our research uses the phrase “restitutionary work” to describe the labour involved. This work goes far beyond diplomacy, logistics and transport. It includes:
- Acknowledgment of injustice: Recognising that items were wrongly taken, whether through violence, coercion, or theft.
- De-objectification: Treating ancestral remains and cultural belongings not as human remains and museum objects but as ancestors or cultural treasures.
- Community involvement: Ensuring that descendant groups and local communities decide what happens after return, in conversation with museums and national governments.
- Healing processes: Creating spaces for mourning, ceremony and closure.
- New futures: Seeing restitution not just as recovering the past but as opening pathways for cultural renewal and social justice.
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For example, South Africa’s land restitution programme has shown that restitution is not simply about restoring what once was. It is about creating conditions for justice today and possibilities for tomorrow.
Similarly, cultural restitution is less about putting things “back where they came from” and more about empowering communities to reconnect with their heritage in ways that matter today.
Why words matter
The distinction between repatriation and restitution is not academic nitpicking. Words shape power. If return is framed as repatriation, the emphasis is often on the giver, the returner, in the form of the state or museum, granting something back. If it is framed as restitution, the emphasis shifts to the claimant, to the community asserting rights and demanding justice.
Restitution is not about recovering a lost past. That past cannot be restored exactly as it was. Instead, it is about creating new futures built on justice, dignity and respect. For communities around the world still living with the legacies of colonial dispossession, that distinction matters deeply.
Victoria Gibbon, Professor in Biological Anthropology, Division of Clinical Anatomy and Biological Anthropology, University of Cape Town
Ciraj Rassool, Senior Professor of History, University of the Western Cape
