Listing Rule 21

Witan Investment Trust PLC
02 July 2004

WITAN INVESTMENT TRUST PLC

HENDERSON GLOBAL INVESTORS

2 JULY 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 30 June 2004:
Company
BP
HSBC
Vodafone
Shell Transport & Trading
GlaxoSmithKline
Barclays
Royal Bank of Scotland
British American Tobacco
HBOS
AstraZeneca





                                    - ENDS -



For further information, please call:

James Budden

Witan Investment Trust plc

Tel: [phone]

or

Gordon Puckey

Quill Communications

Tel: [phone]


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