The Crossword Centre Clue-Writing Competition

CCCWC July competition voters’ comments
Clue no. 24: I deny, as ever, any way to surrender? (5,3,3)

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A clue to NEVER SAY DIE.
3 comments refer to this clue (from 3 competitors, 0 others)

Here is the text

Comments on the clue
1.Role of “to surrender”
2.Not &lit – “to surrender?” is not part of wordplay, and as a semi-&Lit “surrender?” is an anti-def so unfair
3.I can’t see what ‘to surrender’ contributes to the wordplay.