Farmers lose High Court challenge over Labour's inheritance tax changes

A High Court challenge brought by farmers against Labour's inheritance tax reforms has been dismissed by judges today.

Thomas Martin, along with his father George Martin and the campaign group Farmers and Businesses for Fair Tax Reliefs, pursued legal action against the Treasury and HMRC.

They argued that ministers had unlawfully restricted the consultation process.

The claimants did not seek to overturn the tax changes themselves.

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Lady Justice Whipple, delivering the written ruling alongside Mr Justice Fordham, concluded that the challenge had no substantive foundation.

She said: "The claim lacks substantive merit because there never was any legitimate expectation to a consultation of the sort claimed by the claimants."

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

The farmers' legal team, led by Aparna Nathan KC, argued at a March hearing that Government policy required formal written public consultations with affected taxpayers before implementing significant changes to tax regimes.

However, Mark Fell KC, representing the Treasury and HMRC, countered that this commitment was not absolute and applied only "where possible".

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.

Beyond finding the case lacked merit, the judges identified further grounds for dismissal.

They ruled that the legal challenge had been filed too late to proceed.

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Additionally, the court determined that the matter could not properly be adjudicated due to parliamentary privilege, which protects certain governmental and legislative processes from judicial scrutiny.

The modifications to agricultural property relief and business property relief from inheritance tax were first unveiled during the autumn 2024 budget.

The changes took effect on April 6 this year.

A consultation document was subsequently released by the Government on February 27 2025.

According to Ms Nathan, this document addressed only a very narrow portion of the tax alterations.

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.

Throughout the proceedings, Treasury and HMRC lawyers maintained that the claim was without foundation.

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