Listing Rule 21

Witan Investment Trust PLC
02 April 2004


WITAN INVESTMENT TRUST PLC

HENDERSON GLOBAL INVESTORS

2 APRIL 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 March 2004:

Company

BP

Vodafone

HSBC

GlaxoSmithKline

Shell Transport & Trading

Royal Bank of Scotland

Barclays

AstraZeneca

British American Tobacco

HBOS




                                    - ENDS -



For further information, please call:

James Budden

Witan Investment Trust plc

Tel: [phone]

or

Gordon Puckey

Quill Communications

Tel: [phone]


                      This information is provided by RNS
            The company news service from the London Stock Exchange