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[1991] 1 QB 564; [1990] 3 WLR 13, 1 All ER 737. Although s.13 of the Sale of goods act (1979) has traditionally been interpreted very firmly in favour of the buyer, this case seems to restore the balance somewhat. s.13 says that the goods sold should match the seller's description of them. In this case the seller, who specialized in British contemporary art, offered a painting which he claimed to be by the German expressionint Munter. However, he made it clear that he was not an expert on German paintings, and the seller should examine the painting for himself. This he did, and bought it. Later the painting turned out to be a forgery. The Court of Appeal held that he could not recover his purchase price from the seller, because he had not relied on the description in making a purchase; it was therefore not a 'sale by description' for the purposes of s.13. The effect of this case is to ensure that not every sale that is accompanied by a description of the item can be taken to be a 'sale by description'.