United States securities and exchange commission logo

                          February 2, 2021

       Richard Byworth
       Chief Executive Officer
       Diginex Ltd
       35/F Two International Finance Centre
       8 Finance Street, Central
       Hong Kong

                                                        Re: Diginex Ltd
Statement on Form F-1
                                                            Filed January 29,
                                                            File No. 333-252530

       Dear Mr. Byworth:

              This is to advise you that we have not reviewed and will not
review your registration

               Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you
       that the company and its management are responsible for the accuracy and
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

                                                        Please contact Taylor
Beech at 202-551-4515 with any questions.


                          Division of Corporation Finance

                          Office of Trade & Services
       cc:                                              David A. Sakowitz, Esq.