High Court fast-tracks judicial review into inheritance tax relief reforms

"Following what the court described as "regrettable administrative delays" in handling the case, the claimants sought judicial intervention to accelerate proceedings. On 19 January 2026, Mrs Justice Lang ordered that the case proceed to a rare "rolled-up" hearing, covering both permission to bring the judicial review and the substantive merits of the claim. The two-day hearing will take place in February or March 2026, with the court recognising that the issues raised are time-critical and of significant public importance."

"At the heart of the challenge is the claimants' argument that the Government acted unlawfully by conducting only a limited technical consultation on a narrow aspect of the proposed APR and BPR reforms. They argue this fell short of established public law standards, particularly given the scale of the potential impact on farming families, business owners and the wider agricultural and commercial economy."

"The claimants say the lack of a full and meaningful consultation breached the Government's own consultation principles and denied affected taxpayers the opportunity to influence policy before it was finalised."

The High Court granted an urgent hearing for a judicial review challenging Government proposals to change inheritance tax reliefs for farms and family businesses. Claimants include Alvarez & Marsal, Thomas Martin, George Martin and campaign group Farmers and Businesses for Fair Tax Relief, represented by Collyer Bristow LLP. The challenge targets changes to Agricultural Property Relief (APR) and Business Property Relief (BPR). The court ordered a rolled-up hearing covering both permission and merits after noting "regrettable administrative delays." A two-day hearing will be held in February or March 2026. Claimants argue the Government carried out only a limited technical consultation, breaching consultation principles and public law standards. The Speaker of the House of Commons was granted permission to intervene on parliamentary privilege and separation of powers issues.

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