Holding in Company

Tullow Oil PLC
8 January 2002


Tullow Oil Plc

8 January 2002

Re: Holding in Company



A Letter from Zurich Scudder Investments dated 24 December 2001 to Tullow Oil
Plc, received by Tullow Oil Plc 4 January 2002.

Section 198 Companies Act 1985

In accordance with the provisions of the above Section, on behalf of Zurich
Financial Services and its Group, we would inform you of a notifiable interest
in the shares of your Company, which are held as detailed on the attached
schedule.



Alan Kaye

Company Secretarial Department

Zurich Scudder Investments



                                Tullow Oil Plc

                                                           Ordinary 10p Shares

Registered Owner
Littledown Nominees Limited   A/C  05577      385,000
Littledown Nominees Limited   A/C  21667      880,000
Littledown Nominees Limited   A/C  07203      1,685,040
Littledown Nominees Limited   A/C  07197      1,574,800
Littledown Nominees Limited   A/C  05576      6,300,000
Total:                                       10,824,840

Notes:

Littledown Nominees Ltd is a nominee for the ZFS Group subsidiaries: Allied
Dunbar Assurance plc, Zurich Financial Services UK (AD) Pension Scheme; Eagle
Star Insurance Company Ltd; Eagle Star Life Assurance Company Ltd; Zurich
Financial Services UK Pension Trustee Limited; Eagle Star Executives Pension
Trustee Ltd; Eagle Star Securities Ltd; Sceptre Trust Ltd; Home & Overseas
Insurance Company Ltd; Zurich Scudder Pension Managers Ltd; and J.P. Morgan
Trustee and Depositary Company Ltd, the Trustee for Eagle Star Unit Managers
Ltd and the Depository to Threadneedle Investment Funds ICVC.

ZFS is Zurich Financial Services, a company incorporated in Switzerland.

This notification is made on behalf of:

Allied Dunbar Assurance plc;

Eagle Star Life Assurance Company Ltd and Eagle Star Holding Limited;

Zurich Scudder Investments Ltd, Zurich Scudder Pension Managers Ltd and Zurich
Scudder Investments Holdings Ltd.

Allied Zurich Holdings Ltd, Zurich Scudder Investments Inc, ZKI Holding
Corporation, Zurich Financial Services (UKISA) Ltd, Zurich Group Holding,
Zurich Holding Company of America Inc, Zurich Insurance Company and Allied
Zurich plc, the intermediate holding companies of the aforementioned companies
and Zurich Financial Services, their ultimate holding company.

The shares could be available for lending and this could lead to a short term
re-registration.

Total Shares: 356,807,138 = 3.03%