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                           March 16, 2023

       Herman Billung
       Chief Executive Officer
       Himalaya Shipping Ltd.
       S.E. Pearman Building, 2nd floor
       9 Par-la-Ville Road
       Hamilton HM 11, Bermuda

                                                        Re: Himalaya Shipping
Ltd.
                                                            Registration
Statement on Form F-1
                                                            Filed February 27,
2023
                                                            File No. 333-270337

       Dear Herman Billung:

              We have reviewed your registration statement and have the
following comments. In
       some of our comments, we may ask you to provide us with information so
we may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-1

       Prospectus Summary
       Listing, page 12

   1.                                                   We note your disclosure
that your previously issued common shares will remain listed on
                                                        the Euronext Expand and
you intend to file the Norwegian Prospectus before the
                                                        Norwegian FSA for the
admission to listing and trading of the common shares offered in
                                                        this public offering on
Euronext Expand, upon which approval the Company intends to
                                                        publish the Norwegian
Prospectus and your common shares will be tradeable from the
                                                        New York Stock Exchange
to the Euronext Expand. We also note your related disclosure
                                                        on page 39 that your
common shares issued in this initial public offering will not be
                                                        immediately tradeable
between the New York Stock Exchange and Euronext Expand.
 Herman Billung
FirstName  LastNameHerman Billung
Himalaya Shipping  Ltd.
Comapany
March      NameHimalaya Shipping Ltd.
       16, 2023
March2 16, 2023 Page 2
Page
FirstName LastName
         Please revise to clarify whether investors will be able to purchase
shares in one market
         and sell shares in the other market. If so, also explain how trading
between the exchanges
         would operate.
Risk Factors
Our bye-laws provide that the federal district courts of the United States of
America are the sole
and exclusive forum, page 44

2.       We note your disclosure regarding your exclusive forum provision in
your bye-laws.
         However, such provision does not appear to be set forth in your
amended bye-laws filed
         as Exhibit 3.3. Please revise or advise.
Use of Proceeds, page 47

3.       Please disclose the estimated net amount of the proceeds broken down
into each principal
         intended use thereof. See Item 3.C of Form 20-F. In that regard, we
note that you have
         not disclosed the amount of proceeds that you intend to use to pay for
the costs of the
         scrubbers you describe in this section.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Bridge Facility, page 63

4.       We note your disclosure regarding the Bridge Facility with DNB
Markets. Please file
         such agreement as an exhibit, or provide your analysis as to why such
agreement is not
         required to be filed. Refer to Item 601 of Regulation S-K.
Description of Share Capital, page 119

5.       We note your response to prior comment 6 that indicates the waiver
would not be
         effective as a waiver of the right to sue for violations of the
Securities Act or the
         Exchange Act. If you do not intend for this provision to be applicable
to actions under the
         Securities Act or Exchange Act, please revise to state this
information, and tell us how
         you will inform investors in future filings that the provision is not
intended to apply to any
         such actions. In addition, we note your disclosure regarding the
exception in the provision
         for actions involving fraud or dishonesty. However, it does not appear
that such exception
         is included in the provision as set forth in your amended bye-laws
filed as Exhibit 3.3.
         Please revise or advise.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Herman Billung
Himalaya Shipping Ltd.
March 16, 2023
Page 3

       You may contact Lily Dang, Staff Accountant at 202-551-3867 or Mark
Wojciechowski,
Staff Accountant at 202-551-3759 if you have questions regarding comments on
the financial
statements and related matters. Please contact Michael Purcell, Staff Attorney
at 202-551-5351
or Laura Nicholson, Special Counsel at 202-551-3584 with any other questions.



                                                          Sincerely,
FirstName LastNameHerman Billung
                                                          Division of
Corporation Finance
Comapany NameHimalaya Shipping Ltd.
                                                          Office of Energy &
Transportation
March 16, 2023 Page 3
cc:       James McDonald
FirstName LastName