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September 5, 2017

Iraqi pawns and an American chess player

Image Credit: U.S. Embassy Baghdad

The United States has returned dictator Saddam Hussein’s chess set to the Iraqi government in Baghdad but has not given much in the way of details as to who the set had been stolen by or where it has been recovered.

Image Credit:
U.S. Embassy Baghdad

The gameboard and its pieces went missing in 2003.  U.S. coalition forces invaded Iraq in an operation dubbed Operation Iraqi Freedom between March 20th and May 2003 signalling the start of the Iraq War.  Hussein’s Ba'athist Iraqi government was deposed less than a month later.   Hussein himself was captured in December 13, 2003 and was executed in December 2006, having been convicted of crimes against humanity by the Iraqi Special Tribunal.

Image Credit:
U.S. Embassy Baghdad
Whoever made off with this little piece of costly war booty had a good eye, even if it appears that the object was not treated gently as it made its passage from the Middle East to the United States. 

A similar Austro-Hungarian enamelled, parcel-gilt silver and stone-inset chess set was sold at Sotheby’s in its New York April 22, 2010 auction for $35,000


Another set sold at Doyle's, New York, Belle Epoque sale on September 23, 2009, lot 209 ($28,125). Provenance: Property from a Private Collection, Fontana, CA. Condition. 

Five years ago a Christie’s consignor (property of a private collector in Pittsburg) made a healthy profit during its New York April 18, 2012 auction selling theirs for $32,500.


All proving that years after the invasion, auction houses in the U.S. wouldn't have had any trouble selling this Saddam-era bauble, which, like many others, may be traceable back to U.S. government employees and contractors who took items as souvenirs or war trophies. 

September 4, 2017

Egyptian Mummy Cartonnage on Pawn Stars


On this blog we spend a lot of time stressing provenance, provenance, provenance, and the need for antiquities collectors and dealers to perform satisfactory due diligence before purchasing or selling an ancient object.  

Now granted one shouldn't judge the efforts of the entire ancient art collecting community against a single episode of a TV program, but this recent clip, showing the sale of Egyptian mummy cartonnage on The History Channel's popular staged reality TV show Pawn Stars serves as a good reminder of how little an object's legitimacy in the art market, enters into the discussion between buyer and seller when art transactions are filmed for television.  


Pawn Stars has been a History Channel staple since 2009. Filmed on site at the Gold & Silver Pawn Shop in Las Vegas, each episode is framed around the buying, selling, and appraising of items of historical value.

To keep their audiences coming back for more, the program is fast paced and edited to fit several transactions into each episode, in some cases sourcing objects in advance of the program's shooting.  For important pieces there is time allocated for pop-in appraisals by "experts" alongside the requisite name dropping of corporate sponsors, spiced up with a dash of comic relief to keep the audience coming back year after year. 

While I can understand that the show's viewers probably wouldn't tune in to a History Channel series for eight years if the show were to spend a chunk of its expensive air time ensuring that the objects being bartered wer not looted or stolen, but sometimes making a fast buck has led to problems.  

One Season 6 episode "Shekel and Hyde" featured a gentleman who sold a shekel of Tyre to the owners of the Pawn Shop for $1,600.  Unfortunately the coin was apparently stolen.

This is the reason why we keep beating the already dead due diligence horse and why we encourage buyers and sellers of ancient objects to look at the origins of an object before they make a purchase.   But not everyone is interested in ensuring that the objects they want to purchase have not been stolen or looted or come with proper documentation showing compliance with export regulations.

In addition to the mummy cartonnage, Pawn Stars has featured other items of the type that are at risk of being trafficked, again without presenting any information as to if the object was appropriately vetted off camera to ascertain its licit status prior to filming.  

Some of these objects include:  



and 



TV shows the History Channel’s Pawn Stars, American Pickers  and PBS’ Antiques Roadshow attract millions of viewers, as everyone likes the idea of a secret treasure.  Unfortunately the producers of these programs miss a valuable opportunity to educate buyers and sellers, promoting ethical trading in the pieces of the past. 

By:  Lynda Albertson




August 31, 2017

UK Art dealer arrested in Los Palacios, Spain for stealing antiques and on an order of extradition to Italy

Objects seized.  Image Credit: Guardia Civil / DGGC
Identified during a routine inspection of guest lists for lodgings in Los Palacios y Villafranca, a city located in the province of Seville, Spain's Guardia Civil, has detained a British citizen on August 16, 2017 on an arrest and extradition warrant from Italy for the alleged theft of antiquities and cultural heritage objects.

Reported Tuesday, August 29, 2017 in a published statement by the Civil Guard, the detainee, was listed simply with his initials, W.T.V.  At the time he was detained, he was found to be in the possession of 140 objects, including ancient oil lamps, ancient Roman and Arab origin coins, rings, clay tiles and five burner phones. Despite the large quantity of artefacts in his possession, authorities have stated the arrestee was unable to show proof of legal ownership.  

While the full name of the individual was not stated in the press release, the arrestee's initials belong to an expatriate Hungarian coin dealer named William Veres who once managed a company named Stedron based in Zurich, Switzerland.  Veres is known to have worked out of both the UK and Spain and has had his name attached to various illicit activities. 

If Vere's name sounds familiar it is because we mentioned him on this blog one week ago.  He is one of two individuals prosecuted for his earlier role in the illicit sale of a $1.2 million fourth century BCE gold phiale forfeited to Italy by Michael Steinhardt following a lengthy court case and appeals in the United States. 

Working with the Carabinieri in Italy it will be interesting to see what Spain's Guardia Civil will be able to determine regarding the provenance of the objects found in this dealer's possession.  

Now in custody, he will likely be sent back to Italy via the European Arrest Warrant (EAW) system, applied throughout the EU to replace Europe's old lengthy extradition procedures within the territorial jurisdiction.  Through the EAW crime suspects are extradited at the request of foreign countries without the evidence against them being examined in the court of the country where they are detained. 

An EAW may be issued by a national judicial authority if:
  • the person whose return is sought is accused of an offence for which the maximum period of the penalty is at least one year in prison;
  • he or she has been sentenced to a prison term of at least four months.
Having appeared before a judge at a closed hearing in Madrid, it is not yet clear if Veres has agreed to being extradited or whether he will fight the attempt to return him to Italy to face prosecution.

Updates on Turkey’s lawsuit over the multimillion-dollar, 5,000-year-old antiquity known as the Guennol Stargazer.


On August 28, 2017 attorneys for Michael Steinhardt and Christie's filed a lengthy, contentious Motion to Dismiss in the US District Court (SD/NY) related to CIV. ACT. NO. 17-cv-3086 (AJN), Turkey’s lawsuit over the multimillion-dollar, 5,000-year-old antiquity known as the Guennol Stargazer

Screenshot from “The Exceptional Sale,” April 2017
Image Credit: Christie’s New York
The "motion to dismiss" in this case seeks a court order to dismiss the plaintiff's claim on the statutory grounds that such a claim was untimely brought.

Under New York law, barring the expiration of the statute of limitations or application of the laches doctrine, one cannot obtain title from a thief unless the present-day possessor's title can be traced to someone with whom the original owner voluntarily entrusted the art.  As a clear title is not possible in the case of the Guennol Stargazer, it will be up to Steinhardt and Christie's attorney to make a case on the laches defense, where it is clear that the plaintiff, in this case Turkey, unreasonably delayed in initiating an action and a defendant(s) are unfairly prejudiced by the delay.

The purpose of the doctrine of laches is to safeguard the interests of good faith purchasers, in this case of lost/stolen art, by weighing in the balance of competing interest, the owner's diligence in pursuing their claim.   

While delay in pursuing a claim for the Stargazer is generally considered in the context of laches under New York law, it has long been the law of this state that a property owner, having discovered the location of its lost property, cannot unreasonably delay making demand upon the person in possession of that property.

Attorneys for the defendants believe that the repatriation lawsuit must fail as there is evidence that Turkey knew about the Stargazer’s location for longer than three years before it sued, providing the court with a graphic charting that shows when the object first became publicized, implying Turkey's claim, twenty years after its first public announcement, is unreasonable.

The auction home points out that given that the idol’s arrival in the US, it has been referenced on numerous occasions  in museum catalogues and educational publications. 

August 27, 2017

While London's Art and Antiques is suspended, Mexico creates new federal police division to protect cultural heritage

Course Opening Ceremony Image Credit: INAH
While a lot of the art crime news recently has been about the (hopefully temporary) shuttering of New Scotland Yard's Art and Antiques unit in London as its officers are reassigned to work on the Grenfell Tower fire, Mexico seems to be moving in a more positive direction. 


The objective of the pilot course was to establish stronger links between the Secretariats of Culture and the government, in order to ensure the legal care and protection of Mexico's cultural heritage  as stipulated in the country's federal law on Monuments and Archaeological, Artistic and Historical Areas.

The government also announced the formation of a database to be developed to help police determine which heritage assets are susceptible to damage or theft as well as a documentary repository for information about investigations. 



Conference - Authenticity, forgery, provenance, and ethics at the Society of Biblical Literature Annual Meeting


The 2017 Society of Biblical Literature Annual Meeting, will be held in Boston on November 18–21, 2017 and will feature an interesting panel on legitimacy and forgery and the ethical and unethical trade and publication of historic archaeological material with limited or no provenance. 

The title of the panel is:  Avoiding Deception: Forgeries, Fake News, and Unprovenanced Material in Religious Studies

Session date and time:  November 19, 2017 from 1:00 PM to 3:30 PM
Rome and Location: Orleans (Fourth Level) - Boston Marriott Copley Place (MCP)

Invited speakers include: 


According to the annual meeting program book this session will delve into the following: 

Why is provenance important? Although the forgery of documents and artifacts has always been a primary concern in religious studies, recent events surrounding the colloquially designated “Jesus’ Wife Fragment” and various unprovenanced fragments touted as part of the Dead Sea Scrolls have propelled scholars into a new era of forgery studies. While some may suppose that scholars are easily able to identify and disprove such items as forgeries, the complicated landscape in which such materials surface and are distributed has necessitated the adaptation of scholarship to remain diligent in preserving authentic items of history for study. This panel will address the challenges facing scholars in identifying and disproving forgeries in our current era. Invited speakers will similarly offer a space to examine the complexities and current status of forgeries in religious studies, identifying ways scholars can navigate the field without perpetuating erroneous materials in their scholarship. Time will be left following the panel for students and faculty to meet and mingle, in order to facilitate networking between scholars interested in similar material.

August 26, 2017

Yes Virginia, there really are honest dealers in the world.


University of Arizona Museum of Art Curator Olivia Miller
authenticating Willem de Kooning’s “Woman-Ochre,”
on Friday, Aug. 4, 2017.  The painting has been missing since 1985
Often times it seems that antique and antiquities dealers are seldom mentioned on this blog unless there is negative news to share.  Today though, ARCA would like to give a shout out to some really swell folks at Manzanita Ridge Furniture & Antiques of Silver City, New Mexico. 

On the day after Thanksgiving, November 29, 1985, an unremarkable couple:  a woman in her mid-50s with shoulder-length reddish-blond hair and a man in his mid-20s, with short, wavy dark hair and a large mustache entered the University of Arizona Museum of Art in Tucson at the start of the day.  Distracting one of the guards in a conversation on the stairs, the man continued upwards to the second floor gallery and quickly sliced Willem de Kooning's painting "Woman-Ochre" by Willem de Kooning, 1954-1955, 30 in. x 40 in., oil on canvas from its frame.   Hiding the painting under his blue water-repellant coat, the thief and his accomplice made their way back downstairs and out the exit in less than 15 minutes.  

For more than thirty years the painting remained missing, until it was scooped up by David Van Auker, who owns Manzanita Ridge Furniture & Antiques when visiting the home of deceased H. Jerome "Jerry" and Rita Alter to assess its contents as part of an estate sale.  Along with his business partners Richard Dean Johnson and Buck Burns Auker purchased the house's contents, including the painting for $2000.

Back at the shop and with a little help from their customers, the trio soon began to realize that they might have a valuable painting on their hands.  Doing a quick internet search on de Kooning, they came across a 2015 article on azcentral.com of one of the artist's paintings, “Woman-Ochre,” that had been stolen in a daring heist from the University of Arizona Museum.  Matching the photograph pictured on the website with the painting in their shop, the guys decided to do the right thing and give the museum a call.


If you want a chuckle, take a look at their video above, taken from their Facebook page here.   It will make your day, because yes Virginia, there really are honest dealers in the world who do the right thing when they find looted art.

August 24, 2017

Theft: The Universitetet i Bergen posts photos of stolen objects to Flickr

The  Universitetet i Bergen has begun uploading images to Flickr of the approximately 400 objects stolen from the University Museum of Bergen in Norway on August 12, 2017. 


Thieves who broke into the museum entered
 through this window on the seventh floor
 of the building. Image Credit: Begin Police
Thieves entered the museum on the Saturday by climbing up a scaffold and breaking a window on the 7th floor.  Currently it is unclear to authorities whether or not the burglary was professional in nature, as apposed to opportunistic. 

Of the items stolen, most appear to be from the Iron Age, Migration Age and Viking Age periods. All the more puzzling as these objects are of historical significance and well documented, so not likely to generate a significant sum if the thieves tried to fence them.

As the public demands an answer as to how 400 objects could be carted away without someone noticing, individuals at the university are trying its best to look towards the recovery of the objects.  In order to spread the word quickly about the impact of the theft, they have established a Facebook group (primarily in the Norwegian language)  Tyveriet på Historisk museum (Burglary at The University Museum of Bergen) and social media hashtags #vikingskatten #vikingtreasure. Their goal being to draw the public's attention to the crime and to make the public aware that these objects may be in circulation.  


August 23, 2017

Hedge Hogs and the Art of Wealth: The Curious Background of Michael Steinhardt


Michael Steinhardt has a long standing record of making astute financial decisions, many of which have led to stellar investment performance earnings totalling in the millions on Wall Street.  Unfortunately his culture capital record: for making careful, sound, and informed decisions when purchasing antiquities for his purported $200 million private collection of art, has been anything but stellar. 

As Master of the Hedge Fund Universe, Steinhardt has the liquidity to be choosy about his art purchases. With a current net worth of $1.05 billion, according to a 2017 article in Forbes Magazine, and almost thirty years of collecting experience, he's also a member of Christie’s advisory board.  Tight with the Metropolitan Museum of Art, he has had a Greek Art of the Sixth Century B.C. gallery named after him at the museum. All that to say Steinhardt should be sufficiently well informed about the social and ethical obligations of responsibly acquiring, managing and disposing of items in his burgeoning art collection. 

So why then, with access to so many of the art world's elite, has he chosen to overlook the importance of provenience (country of origin) and provenance (history of ownership) of the objects he fancied BEFORE allowing them to enter or exit his collection and comparing that information within the context of the US and international legal frameworks and abiding accordingly?

I guess traders love to gamble (more on that later) a fortune on their compulsions.

Some of Steinhardt's costly gambles:  

A fourth century BCE gold phiale


November 09, 1995, U.S. Customs agents seized a $1.2 million fourth century BCE gold phiale used for pouring libations from Steinhardt's Fifth Avenue residence on Manhattan's Upper East Side.  The financier appealed the lower court's ruling only to have the decision of forfeiture affirmed by the Second Circuit Court of Appeals.  Despite clear proof that the object was smuggled out of southern Italy, Steinhardt petitioned the lower court's ruling all the way to the United States Supreme Court, in the hopes of retaining the object for his collection. 

The high court found no compelling reason to rehear Steinhardt's case on the basis that the importer had intentionally undervalued the object's worth, transited the object illegally from Sicily to Switzerland, and provided false statements misrepresenting the phiale's country of origin on the objects import documentation. 

The two antiquities dealers involved in the purchase, Robert Haber and William Veres, were each given suspended sentences of one year and ten months imprisonment.  The extent of Steinhardt's culpability though was left vague in the final court filings.  Yet Steinhardt's experience as an art collector and specifically his experience with Haber, with whom he had already purchased some $4-6 million in art objects, raises considerable doubts as to his naïveté.  

The fact that the bill of sale from Haber to Steinhardt's even stipulated that if "the object is confiscated or impounded by customs agents or a claim is made by any country or governmental agency whatsoever, full compensation will be made immediately to the purchaser" gives the impression that both the collector and his dealer were aware of the potential for illegality in the market, and possibly with this object specifically. 

(Il)licit Excavations of Maresha Subterranean Complex 57: 
The ‘Heliodorus’ Cave


In early 2007 Michael Steinhardt acquired the so-called Heliodorus Stele from Gil Chaya, an antiquities dealers in Jerusalem, who is reportedly a nephew of the late Shlomo Moussaieff.  Moussaieff once owned one of the largest collections of biblical antiquities, many of which were unprovenanced.  After the purchase Steinhardt and his wife presented the stele to the Israel Museum in Jerusalem on an extended loan.

The stele contains a magnificent 2nd century BCE Greek inscription which documents a correspondence between the Seleucid king, Seleucus IV (brother of Antiochus IV) to an aide named Heliodorus.  Unsurprisingly though, the bottom portion of the stele was missing, leaving a gap in scholarship as well as a tell-tale signature that the stele had likely been looted upon its extraction, since its base was missing. 

Earlier, during 2005 and 2006 excavations at the Maresha Subterranean Complex 57 at Beit Guvrin National Park three fragments were uncovered that were subsequently identified as matching the bottom of Steinhardt's stele.  These fragments were discovered in a subterranean complex by participants in the Archaeological Seminars Institute's "Dig for a Day" program.  The correlation of the fragments' epigraphy and testing of their stone and soil samples at the find site proved that the fragments were a perfect match, completing missing pieces of the stele.  

It was later determined that the stele had been stolen during a robbery at the Beit Guvrin National Park in 2005.  Tel Maresha's head archaeologist, Dr. Ian Stern verified that he remembered arriving at the site on a Sunday morning in 2005 only to find that the cave where the fragments were later found, had been “turned upside down,” apparently by looters searching for ancient objects to be sold on the black market.  

United States v. One Triangular Fresco Fragment



Despite the object's obvious Italian origin, the shipment had a customs declaration form which falsified the object's country of origin as Macedonia. The fragment was forfeited to the U.S. government and repatriated to Italy on February 24, 2015.

A Sardinian Marble Female Idol of the Ozieri Culture


November 21, 2014 Christos Tsirogiannis identified a $1 million Sardinian marble female idol dating from 2500-2000 B.C.E. scheduled for auction as Lot 85 at Christie's on December 11, 2014 as having been matched with an image he found in the archive of convicted Italian antiquities dealer Giacomo Medici.

Before arriving in the collection of Michael and Judy Steinhardt, the object had previously made its way through Harmon Fine Arts and The Merrin Gallery*, both of New York.  Once part of the collection of pet food giant Leonard Norman Stern, the object was once displayed, but not photographed, in a "Masterpieces of Cycladic Art from Private Collections, Museums and the Merrin Gallery" event in 1990 where both Steinhardt and Stern were present. 

On November 27th the object was pulled from the Christie's auction for further review. Its current status has not be made known publically. 

An Anatolian marble female idol of Kiliya type, AKA The Guennol Stargazer
Screenshot from “The Exceptional Sale,” April 2017
Image Credit: Christie’s New York

On April 29, 2017 at the behest of a request by the Turkish authorities and following the interim judgement of the United States District Court, Christie's applied precautionary measures regarding the sale of the 9-inch, 5,000-year-old a rare 3rd millennium BCE idol, likely looted from the Akhisar district of Manisa province in Anatolia.  Turkey's Culture Minister Nabi Avcı told the press that the auction house will abide by the Court's recommendation for a temporary 60-day hold on the antiquity while an investigation into the object’s provenance is conducted. During that time period, the purchaser’s hammer price + buyer's premium bid of $14,471,500 USD was confirmed but not collected.  As a result of the object being contested, the would-be buyer bowed out from the purchase shortly after to case broke in the international press. 

According to documents, Michael Steinhardt had purchased the Stargazer from Merrin Gallery* in August 1993 for under $2 million.  Had the sale not been halted he would have pocketed $12.7 million for the 5,000 year-old Guennol Stargazer, twice the object's pre-sale estimate.

A Marble Head of a Bull (ca 500-460 BCE)

Marble Head of a Bull (ca 500-460 BCE),
 (image courtesy the Metropolitan Museum of Art, New York
Earlier this month Manhattan prosecutors took custody of a 2,300-year-old marble bull's head, that was on loan to the Metropolitan Museum of Art over suspicions that the antiquity had been pillaged. 

The marble head of a bull was purportedly purchased by Lynda and William Beierwaltes in 1996 for more than US$1 million. The Beierwaltes in turn sold the statue on to Michael Steinhardt in 2010 who later loaned the antiquity to the Metropolitan Museum of Art.  After learning that the object might be subject to seizure, Steinhardt asked that the Beierwaltes take possession of the object and compensate him for his purchase. 

The Beierwaltes have stated they purchased the object through an unnamed London art dealer. NOTE: The Beierwaltes were clients of Robin Symes and Christos Michaelides.

Six examples of high stakes "risks" overlapping with names of antiquities dealers many of whom those who analyse art crimes will already recognize.  

Yearning for Legitimacy or Repeating the Sins of the Father?

Steinhardt says the inherent risk in antiquities collecting doesn’t intimidate him. “It is a little bit dangerous, but that is what makes it exciting,” ....“But life is filled with risks, isn’t it?”

Understandably, leading a life on Wall Street makes you look at risk differently than the average person, and hedge fund overlords thrive on tightrope walking high-risk investment tactics in order to bring in lucrative returns.  In a world designed to aggressively accumulate wealth, it's not surprising that Michael Steinhardt approached his art acquisitions apparently enjoying the adrenalin-filled rush from the risk-taking he took.  

Yet with so many examples of getting it wrong; electing to overlook the provenance of the objects he collected in favor of the buy, working with dealers already known to raised eyebrows or prosecutions for undocumented artifacts, and irregular import documentation, Steinhardt's maneuvers shouldn't be interpreted as simple novice mistakes made by a collector with more money than Midas. Despite that, Steinhardt has profited more than he has been held in account for, which shows, unfortunately, that the odds remain remarkably in his favor, despite the alleged illicit purchases. 

Risk vs. Payoff: Lessons from Childhood

But before the legendary Wall Street money manager stepped into the collector's ring, Steinhardt was brought up in working-class Bensonhurst, Brooklyn.  He is the son of the late Sol Frank Steinhardt, a reputed gambler and jewelry fence, who was a  lieutenant of the prohibition era crime boss Meyer Lansky.  Lansky was one of the most notorious of the Jewish crime bosses and a valuable money-maker for Joe Masseria's organization which made much of their income through extortion and is reputed to have been one of the most violent gangs of the era.

A gambler, "Red" Steinhardt, as Sol was also sometimes called, partnered with Lansky in Florida and Havana on gambling rackets that helped finance the National Crime Syndicate, alongside Vincent "Jimmy Blue Eyes" Alo, a New York mobster and a high-ranking Capo in the Genovese crime family. 

Before long, Sol Steinhardt's dealings as a farbrekher got him arrested, and in 1958 he was sentenced to 5-10 years on each of two counts for his fencing escapades.   Sol served out his sentence at Sing-Sing prison and Dannemora, the maximum security facility along the Canadian border.  According to Michael Steinhardt's autobiography, Steinhardt Sr. paid for his undergraduate education at the University of Pennsylvania’s Wharton School, – most likely with ill-gotten gains.

Antiquities and Risk 

In 2005 Linda Sandler interviewed Michael Steinhardt on antiquities and risk, after his lost his appeal on the gold phiale.  During the interview he said:


I guess some collectors aren't candidates for sainthood either. 

The moral question is this: Suppose you can legally gain the reward and stick other people with the risk. It is easy enough for me to tell you not to do it. But will it change your action? 

By: Lynda Albertson
----------------------------------------------
* The Merrin Gallery was started by Edward Merrin, now run by his son, Samuel Merrin and Moshe Bronstein, appears in the business records of Sicilian antiquities dealer Gianfranco Becchina, who was charged with receiving and trafficking in looted antiquities.



August 14, 2017

Artefacts seized at Benazir Bhutto International Airport in Islamabad


Destined for Japan, customs authorities at Benazir Bhutto International Airport in Islamabad have intercepted six antiquities believed to date from the 2nd to the 5th Century CE along with ten counterfeit objects.  According to their customs declaration the items were listed incorrectly as simply “decoration items.”  

Instead, according the the Directorate General of Archaeology and Museums in Islamabad, the consignment contained contraband artifacts that come from the kingdom of Gandhara, an ancient Vedic and later Buddhist civilization from the Peshawar valley, which stretches from northern Pakistan to the Kabul River in eastern Afghanistan.

The export of antiquities was banned in Pakistan under Section 24(2) of Section 35 of the Antiquities Act, 1975.   Under this law a “protected antiquity” belongs exclusively to the government and their unauthorized removal or destruction is an offence punishable with rigorous imprisonment of three years or a fine of Rs 200,000 or both.