Collyer Bristow LLP, acting for their professional client Alvarez & Marsal LLP and the Claimants — Thomas Martin, George Martin, and Farmers and Businesses for Fair Tax Relief — announces that the judicial review challenge to the Government’s proposed changes to Agricultural Property Relief (APR) and Business Property Relief (BPR) from Inheritance Tax has been given permission to proceed urgently to a ‘rolled‑up’ hearing in the High Court, covering both the grant of permission to bring the claim and the claim’s substantive merits.

Following what the Court accepted had been “regrettable administrative delays [by court staff] in dealing with this case at various stages”, Collyer Bristow sought judicial intervention to progress the Claim.  Mrs Justice Lang DBE then immediately made an order on 19 January 2026, ruling that a hearing will take place over two days on dates to be announced in February or March 2026, which recognises that the issues raised are important, time‑critical, and require an urgent judicial decision.

In this challenge, the Claimants argue that the Government’s decision to undertake only a limited technical consultation on a narrow aspect of the proposed reforms was unlawful. This was especially damaging given the likely impact of the changes on farming and business‑owning families, UK businesses, and the wider agricultural and commercial sectors. The Claimants say that the lack of a more comprehensive consultation fell well short of longstanding legal standards and breached the Government’s public law duties towards them and others.

Given the potential constitutional significance of some issues before the Court, the Speaker of the House of Commons has been given permission to intervene as an Interested Party. This will allow his Counsel to assist the Court on matters of Parliamentary privilege, the separation of powers between the Courts and Parliament, and the permitted use of Parliamentary materials.

James Austen, the Partner at Collyer Bristow with primary conduct of the claim, said: “The Court’s decision to hear this important case urgently is fantastic news and long overdue. We welcome it, and the Claimants look forward to their day in court. Most significantly, this development means that a High Court judge will rule on whether the Government acted unlawfully in making changes to APR and BPR without first consulting with taxpayers in line with its then-policy. Most judicial review claims fail at the first hurdle and are not given permission to proceed to a full hearing. Further, ‘rolled-up’ hearings are unusual – and for one to be listed so promptly is exceptionally rare. The Administrative Court’s decision reflects the importance of this claim.”

Marvin Rust, Head of Alvarez & Marsal Tax EMEA, said: “We work with many family businesses and farms who need certainty. Limiting longstanding Inheritance Tax reliefs is an important legislative change, which was introduced without proper consultation, contrary to well-established principles. That is not how policy of this magnitude should be made. We welcome the Court’s expedited hearing to determine the lawfulness of the process.”

Tom Martin, the lead claimant, said: “I am very grateful to the teams at Collyer Bristow and Alvarez & Marsal for their commitment and support in bringing this judicial review claim. This legal case matters to everyone affected by the proposed tax changes, and I am proud to speak for the concerns of farmers and business owners whose livelihoods would be impacted. By deciding not to have a proper consultation, the Government improperly denied us the chance to influence the policy and its implementation. I look forward to taking this important case to Court to ensure due process is followed.”

Next Steps

• The Court has issued detailed case management directions to ensure the case proceeds to a hearing without further delay.
• Because Parliament is debating the APR/BPR changes in the draft Finance Bill, which is currently in Committee stage in the House of Commons, it is now too late for the Court to order the Government to carry out a public law-compliant consultation. The Claimants are therefore asking the Court for a declaration that the Government’s inadequate consultation exercise was unlawful. For constitutional reasons, courts may not rule on what Parliament can or cannot debate or decide. If the Court agrees with the Claimants, this will not invalidate the substantive tax changes themselves.
• While the Claimants hope the Government will take the issues raised by this judicial review into account when deciding how (or whether) to proceed, the Government retains full discretion to act as it sees fit.
• Collyer Bristow is instructing Aparna Nathan KC to act for the Claimants in this matter, and she will be presenting their legal arguments to Court in written and oral submissions.

Notes for Editors

• For general enquiries regarding this claim or the press release, please contact Byfield PR at bethany@byfieldconsultancy.com
• For media enquiries specifically relating to the claimants, please contact Soho Communications at jamesc@sohocommunications.com