Portfolio Update

CHELVERTON GROWTH TRUST PLC (the 'Company')

In accordance with UKLA Listing Rule 21.20(l)(ii), the following list
represents the Company's 10 largest investments as at 30th November 2004 and
where appropriate, any investment with a value greater than 5% of the Company's
gross assets:

Name of company                            Class of share
                                                         
AI Claims                                  Ordinary      
                                                         
Bioquell                                   Ordinary      
                                                         
Brandon Hire                               Ordinary      
                                                         
Chelverton Asset Management                Ordinary      
                                                         
Clipper Ventures                           Ordinary      
                                                         
Hamworthy                                  Ordinary      
                                                         
IDOX                                       Ordinary      
                                                         
Merrydown                                  Ordinary      
                                                         
Stanley Gibbons                            Ordinary      
                                                         
Transport Systems                          Ordinary