It all depends on how it is fixed. I assume it is not screwed to the wall. Is it fixed to tiles or directly to the wall with tiles around it? Either way if it is glued on there is going to be a bit of making good after it is removed. A chisel and hammer or an SDS drill with chisel bit would be the tools of choice but there is a danger of doing damage to the surrounding area. Try and get the chisel between the towel rail and the wall. Depending on how hard it is you may be able to drill into it to help break it up.
Good Luck!
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