Michael Caine, ever affable and full of anecdotes, enters the room to face six or seven American newspaper writers who have just seen his new movie, "Without a Clue." And the first thing he does is justify himself.

He would never have cast himself as Sherlock Holmes, he explains, but this movie is a spoof about an actor pretending to be Holmes, so it's OK.Besides, he adds later, it's "Alfie Meets Gandhi."

"Alfie" was Caine's 1966 international hit, of course, and "Gandhi" was the film debut of Ben Kingsley, who co-stars in "Without a Clue" as Dr. Watson.

As this film would have it, Kingsley's Watson is the brains of the duo, a medical doctor with brilliant deductive powers who moonlights by writing detective fiction. But his fictional Holmes has become so popular that he has hired an actor to play the part. Unfortunately, the actor is a bumbling, womanizing drunkard who wouldn't know a clue if it bit him.

Believe it or not, Caine & Kingsley are in slapstick territory . . . and the real surprise is how good at it they are.

Speaking separately to small groups of writers throughout the day _ writers who have been flown to London by Orion Pictures for these interviews _ Caine and Kingsley, along with co-stars Jeffrey Jones and Lysette Anthony, director Thom Eberhardt and producer Marc Stirdivant, all talk about how much fun they had making the picture, how much fun it was to work with each other _ and how much fun it would be to do a sequel.

And, if the reaction of the American critics is any judge, the fun has translated well to the screen.

"Comedy is very hard work," Caine said. "The timing is razor-sharp, and movie comedy is particularly hard because you haven't got an audience. The camera crew on this were a great audience. Sometimes we had to reshoot because the operator was laughing and the camera was shaking."

"We were very lucky in that film," Kingsley said. "The cast is just wonderful.

"I think that it's very good that as well as it being a comedy, it takes themyth very seriously _ it allows Watson to take the myth very seriously. Lots of people said, `You're going to debunk the myth, you're going to stand it on its head.' But it doesn't do that."

"Without a Clue" brings Caine and Kingsley together for the first time, but Caine says they hit it off immediately with no sense of star competition.

"We're very fond of each other," Caine said, "and we're both very experienced actors, too. We're both non-competitive. We just decided the partnership wasthe thing, rather than the individual."

"Michael would describe our relationship as non-competitive," Kingsley said later. "I always think there's something gladiatorial about acting. It's not combative, but you do have to be on your mettle, on your guard, extremely alert. So all the senses that combat provokes are provoked by acting _ but it's not combat. Somewhere you have all the benefits of having a really thrilling fight without really fighting."

Both actors are also quite prolific, turning out what seems to be film after film after film.

"I finished this," Kingsley said, "and then I went to Budapest and filmed the life of (Nazi-hunter) Simon Wiesenthal, `Murderers Among Us,' for HBO.

"(Before `Without a Clue') I did `Testimony,' I played Dmitri Shostakovich in a very big sweep of his life from his first emergence as a conductor/composer to his death.

"And `Lenin.' Lenin's journey from Zurich to St. Petersburg in 1917 in a sealed train that the German high command put him in in order to destabilize Russia. A very bizarre piece of history."

Caine has a workaholic reputation, but says it's undeserved. "I don't make as many (movies) as you think, it's just that they release them all at the same time. There are 365 days in a year and the opening night of `Without a Clue' (Oct. 21 in New York and Los Angeles) is the premiere night on television of `Jack the Ripper.'

"And then I went on and did another picture called `Dirty Rotten Scoundrels' with Steve Martin. I finished that four weeks ago and normally you would expect that to come out next spring. That comes out the 15th of December. They suddenly decided it's their Christmas picture.

"So I've made two pictures and a television (miniseries) over the course of a year and they all come out within six weeks of each other. And they always do that to me. At least you won't have to see anything else with me in it because I'm not working again until February and it won't be out again until next Christmas."

Caine then segues into one of the anecdotes for which he is famous, elaborating on his work and weaving into it a story about Lillian Gish:

"Last year I had two years worth of pictures _ five _ come out within six weeks. A year ago here, in England, I had a picture open every 11 weeks _ they just save them. And I've been making pictures for a very long time and they're on television. So you go home and I'm on television too, and you think, `This guy's everywhere.' And the people who stay up late and watch televison always think everyone they're watching is dead, so they think I'm dead.

"I remember being at the tribute for Alfred Hitchcock and they gave the Lillian Gish scholarship, and the spotlight goes up and just beside me is Lillian Gish, who I thought was dead for years, and she wears white makeup and has gray hair and this spotlight went on her and she had on a white dress and I looked around and suddenly this ghost of Lillian Gish came up. And you get that sort of thing."

Concerned about enraging Sherlock Holmes fans by doing "Without a Clue" as a farce, Caine also detailed two experiences that gave him pause:

"One day I was on the set and the director says, `That's the president of the Sherlock Holmes society.' Fortunately we were shooting a scene where I was playing a real Sherlock Holmes.

"And the fellow says, `Oh, we all loved the script, it's very funny.' I said, `You don't mind?' He said, `No, because you're not playing Sherlock Holmes. You're playing an actor who's playing Sherlock Holmes. So anything you do is OK.' "

Caine said he was living in a temporary flat while his new apartment was being readied and his neighbor, a little old lady, would greet him each day. "Then about three weeks ago she said to me, `You played Sherlock Holmes, didn't you?' So I said, `Yes, I did.' She said, `The American press are coming over here to interview you, aren't they?' I said, `Yes, they are.' She said, `I think one of them is going to interview me.' So I looked at her, I thought, `This woman's nuts.' So I said, `Why is he going to interview you?' She said, `I'm Conan Doyle's daughter.' And this is such a spoof, I'm glad I'm going to be out of the buildingbefore she sees the movie."