Listing Rule 21

Witan Investment Trust PLC
05 January 2004



WITAN INVESTMENT TRUST PLC

HENDERSON GLOBAL INVESTORS

5 JANUARY 2004







                           WITAN INVESTMENT TRUST PLC

                                Listing Rule 21





In accordance with paragraph 21.20 (l) (ii) of the Listing Rules, Witan
Investment Trust plc announces its ten largest investments, including all
holdings with a value greater than 5% of its gross assets, as at 31 December
2003:


Company                          % Gross Assets

HSBC                             3.58

Vodafone                         3.53

BP                               3.38

GlaxoSmithKline                  3.03

Shell Transport & Trading        2.79

Barclays                         2.11

Royal Bank of Scotland           2.10

AstraZeneca                      1.47

HBOS                             1.37

British American Tobacco         1.35





                                    - ENDS -



For further information, please call:

James Robinson

Witan Investment Trust plc

Telephone: [phone]

Stephen Westwood

Head of Investment Trusts

Henderson Global Investors

Telephone: [phone]

Stephen Phillips

Associate Director

Henderson Global Investors

Telephone: [phone]


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