Listing Rule 21

Witan Investment Trust PLC
05 January 2005



WITAN INVESTMENT TRUST PLC

HENDERSON GLOBAL INVESTORS


5 JANUARY 2005


                           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
2004:


Company
BP
Vodafone
HSBC
GlaxoSmithKline
Royal Bank of Scotland
Shell Transport & Trading
Philips Electronics
Barclays
Henderson Strata Investments
Walt Disney


                                    - 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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