High Court Dismisses Farmers' Legal Challenge Over Inheritance Tax Consultation

A High Court challenge brought by farmers against Labour's inheritance tax reforms was dismissed by judges on 2026-05-12. Thomas Martin, his father George Martin and the campaign group Farmers and Businesses for Fair Tax Reliefs had pursued the case against the Treasury and HMRC.

The claimants argued that ministers had unlawfully restricted the consultation process but did not seek to overturn the tax changes themselves.

Lady Justice Whipple and Mr Justice Fordham delivered the written ruling dismissing the claim. "The claim lacks substantive merit because there never was any legitimate expectation to a consultation of the sort claimed by the claimants," Lady Justice Whipple said.

The judges determined that no clear or unambiguous commitment to a comprehensive consultation on the proposed reforms had ever been made.

The court also ruled that the legal challenge had been filed too late to proceed. Additionally the judges found that the matter could not properly be adjudicated due to parliamentary privilege. GB News reported that these procedural grounds provided further reasons for dismissal beyond the lack of substantive merit.

The farmers' legal team was led by Aparna Nathan KC. At a March hearing she argued that Government policy required formal written public consultations with affected taxpayers before implementing significant changes to tax regimes. According to Aparna Nathan KC the February 27 2025 consultation document addressed only a very narrow portion of the tax alterations.

Mark Fell KC represented the Treasury and HMRC. He countered that the commitment to consultation was not absolute and applied only "where possible". Treasury and HMRC lawyers maintained throughout the proceedings that the claim was without foundation.

The modifications to agricultural property relief and business property relief from inheritance tax were first unveiled during the autumn 2024 budget. The inheritance tax changes took effect on April 6 2025. The Government released a consultation document on February 27 2025.

The claimants maintained that ministers had acted unfairly and violated principles of good administration by failing to apply their own consultation policy to these reforms. GB News reported that the farmers' case centred on their contention that the Government had breached its own standards by failing to conduct thorough consultation before implementing such substantial reforms.