THE HEADLINE ISSUE

The Government plans to reform Agricultural Property Relief (APR) and Business Property Relief (BPR) - two long-standing reliefs designed to protect family businesses and family farms from inheritance tax burdens.

Despite the significant legal, financial and generational impact these reforms would have, the Government is pressing ahead without consulting stakeholders in breach of public law duties and contrary to its own published tax policy principles.

🔹 WHO IS BRINGING THIS CHALLENGE?

The lead claimant is Tom Martin, a sixth-generation farmer near Peterborough.  He is joined in the claim by his father, George Martin, and a representative association, formed by and for farmers and family-owned businesses who rely on APR/BPR to preserve business continuity, ensure food security, and sustain the UK’s rural economy and family businesses which form the backbone of the UK's economy. Law firm Collyer Bristow LLP have conduct of the claim, with representation from leading counsel, Aparna Nathan KC.

🔹 WHY THIS MATTERS       

This is not just a technical tax change, it is a direct threat to the economic and social fabric of the UK’s rural and family business sectors. 

Around 100,000 family-run farms stand to be adversely impacted by the proposed changes to APR and BPR. Thousands more non-farming family businesses from rural manufacturers to multi-generational service firms also face existential jeopardy. Together, these changes put hundreds of thousands of jobs at risk, many in fragile rural economies already under strain.

Removing these reliefs without consultation doesn’t just punish responsible succession planning, it creates a crippling uncertainty for families who have invested in building sustainable, long-term enterprises. 

If the proposed changes remain unchanged:

Farms will be forced to sell land to pay inheritance tax bills, fragmenting holdings built up over generations, pushing them into unviability

Small and mid-sized businesses may be forced to break up or sell under duress

UK food security will be weakened as the capacity of domestic agricultural production declines

The next generation of farmers and entrepreneurs will face punishing barriers to entry

Above all, the Government’s refusal to consult sets a dangerous precedent: that major tax policy can be made by executive fiat, without evidence, scrutiny, or warning. 

All that the Claimants ask is that the Government conducts a full consultation on this policy, so that there is a clear understanding of its impact and an opportunity to suggest alternatives.

This case is about more than tax—it’s about transparency, trust, and the fair treatment of those who feed us, employ us, and build for the long term. 

🔹 THE LEGAL ARGUMENT

This Judicial Review is based on four principal grounds:

• Breach of Duty to Consult: The Treasury is under a public law duty to consult before major tax reforms and a failure to do so may be unlawful.
• Breach of Legitimate Expectation: Repeated Government policy documents have promised consultation. A failure to follow through once taxpayers have place reliance on a promise to their detriment may be held to be unlawful.
• Failure to follow Policy:  The failure by a public body to follow a policy that it has lawfully created is unlawful.  The Government’s failure to follow its own policy to consult on major tax changes is said by the Claimants to be unlawful.
• Breach of Principle of Legality (fairness): The duty to act fairly is an important duty imposed upon any public body. The lack of transparency, absence of impact assessments, and disregard for sector-specific vulnerability (e.g., tenant farmers, elderly landowners) breaches the principle of legality.

This case is strengthened by the EFRA Select Committee’s recent findings, which expressly called for consultation and highlighted the risks to family farms and rural resilience.

🔹 FUNDING NEED

• £250,000 is required urgently to fund the case through court. Any money donated through this page will be directed to the costs associated with this claim.
• It is difficult to predict the exact legal costs but by all supporting we have an opportunity to collectively stand up for the farming and family business community in the UK.
• The case is being backed by privately owned businesses and a growing number of rural advocates, but wider support is critical.
• In the event that there is an excess of funds raised, the surplus will be paid in accordance with CrowdJustice’s terms.

🔹 CALL TO ACTION

“This is not just about tax - it’s about trust, fairness and constitutional accountability. If the Government can dismantle long-standing tax protections without warning, without evidence, and without consultation, then no one is safe. This challenge is about forcing transparency and safeguarding the future of British farming, small business and the rural economy.”

• Please donate if you can
• Share this page with your networks
• Write to your MP – especially if they represent rural communities or sit on relevant committees

THANK YOU FOR YOUR SUPPORT - TOGETHER WE WILL FIGHT FOR FAIRNESS