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                              August 4, 2023

       Roland Kohl
       Chief Executive Officer
       Highway Holdings Ltd.
       Suite 1801, Level 18, Landmark North 39 Lung Sum Avenue
       Sheung Shui
       New Territories, Hong Kong

                                                        Re: Highway Holdings
Ltd.
                                                            Form 20-F for the
Fiscal Year Ended March 31, 2023
                                                            File No. 001-38490

       Dear Roland Kohl:

              We have limited our review of your filing to the submission
and/or disclosures as
       required by Item 16I of Form 20-F and have the following comment. In our
comment, we may
       ask you to provide us with information so we may better understand your
disclosure.

              Please respond to this comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond.

                                                        After reviewing your
response to this comment, we may have additional comments.

       Form 20-F for the Fiscal Year Ended March 31, 2023

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 45

   1.                                                   We note that during
your fiscal year ended March 31, 2023 you were identified by the
                                                        Commission pursuant to
Section 104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15
                                                        U.S.C. 7214(i)(2)(A))
as having retained, for the preparation of the audit report on your
                                                        financial statements
included in the Form 20-F, a registered public accounting firm that
                                                        has a branch or office
that is located in a foreign jurisdiction and that the Public Company
                                                        Accounting Oversight
Board had determined it is unable to inspect or investigate
                                                        completely because of a
position taken by an authority in the foreign jurisdiction. Please
                                                        provide the
documentation required by Item 16I(a) of Form 20-F or tell us why you are
                                                        not required to do so.
Additionally, please amend your Form 20-F to provide the
                                                        disclosures required
under Item 16I(b) of Form 20-F. Refer to the Staff Statement on the
                                                        Holding Foreign
Companies Accountable Act and the Consolidated Appropriations Act,
                                                        2023, available on our
website at https://www.sec.gov/corpfin/announcement/statement-
                                                        hfcaa-040623.
 Roland Kohl
Highway Holdings Ltd.
August 4, 2023
Page 2

        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 Kyle Wiley at (202) 344-5791 or Jennifer Gowetski at
(202) 551-3401
with any questions.



                                                          Sincerely,
FirstName LastNameRoland Kohl
                                                          Division of
Corporation Finance
Comapany NameHighway Holdings Ltd.
                                                          Disclosure Review
Program
August 4, 2023 Page 2
cc:       Istvan Benko
FirstName LastName