Phryne, an Athenian courtesan said to be the mistress of Praxiteles, was accused of impiety. The judges, however, refused to condemn her when her counsel made her remove her clothes to reveal her perfect beauty.
Falguière was commissioned by the art dealer and fondeur Jean Goupil, father-in-law of Gérôme, to model the central figure of the latter's painting Phryne before the Areopagus, exhibited at the Salon in 1861. The work was also executed in marble and ivory and, as with the present bronze, examples are invariably unsigned. See Christie's Amsterdam, 15 May, 1983, lot 575, for a cast by the Goupil foundry, signed by Falguière.