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                               April 15, 2024

       Raymond Wai Man Cheung
       Chief Executive Officer
       Basel Medical Group Ltd
       6 Napier Road
       Unit #02-10/11 Gleneagles Medical Centre
       Singapore 258499

                                                        Re: Basel Medical Group
Ltd
                                                            Amendment No. 1 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted March 18,
2024
                                                            CIK No. 0002004489

       Dear Raymond Wai Man Cheung:

                                                        We have reviewed your
draft registration statement and have the following comments.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

               After reviewing the information you provide in response to this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional comments.

       Amendment No. 1 to Draft Registration Statement on Form F-1 submitted
March 18, 2024

       Cover Page

   1.                                                   We note your disclosure
on the cover page and Summary that you expect that you will be
                                                        a controlled company
following the completion of the offering. Please include risk factor
                                                        disclosure that
discusses the effect, risks and uncertainties of being designated a controlled
                                                        company, including but
not limited to, the result that you may elect not to comply with
                                                        certain corporate
governance requirements.
       Prospectus Summary, page 1

   2.                                                   Please revise to
clarify when Basel Medical was incorporated in the British Virgin Islands.
                                                        We note your disclosure
on page 3 that your founder started practicing in Singapore in
                                                        2001 and your first
clinic was set up and incorporated in 2004. We also note your
 Raymond Wai Man Cheung
FirstName   LastNameRaymond  Wai Man Cheung
Basel Medical   Group Ltd
Comapany
April       NameBasel Medical Group Ltd
       15, 2024
April 215, 2024 Page 2
Page
FirstName LastName
         disclosure on page 31 that Basel Medical was incorporated on August
10, 2023 as part of
         your Group   s corporate reorganization to prepare for this listing.
3.       We note your prominent disclosure in the Summary of your plans to
provide medical
         services to patients across Singapore    and beyond    and that you
plan to expand
         geographically    across the region.    Please balance your disclosure
to clarify, if true, that
         your business strategy is to expand in neighboring places within the
Asian region, such as
         Malaysia. We refer to your disclosure on page 57.
Risk Factors
Increase in operating costs, namely lease rental rates and risk of relocation,
may cause disruption
to our business operations, page 14

4.       We note your previous disclosure that you "are not dependent on any
lease or other direct
         agreements with Gleneagles Medical Centre," although you utilize their
         facilities. However, in a subsequent risk factor you state you "lease
the premises of [y]our
         existing clinics," which are located at the Gleneagles Medical Centre.
In your first
         disclosure, please revise to clarify that you are dependent on your
leases at Gleneagles
         Medical Centre with certain landlords.
We face potential risks associated with the handling of personal information
and medical data,
page 15

5.       We note that you rely on computer systems and network infrastructure
to collect, process,
         and store sensitive and confidential data. Please disclose any
potential or successful
         breaches, human errors, or similar events that have created an adverse
cybersecurity event,
         or state that there have been no such events to date. Please also
include any steps towards
         mitigating such risks the company has considered or taken.
We may not have adequate insurance coverage in place, page 17

6.       Please revise to clarify whether your practice, including the medical
practitioners and any
         other practice providers, maintains professional malpractice
insurance.
Special Note Regarding Forward-Looking Statements and Industry Data, page 28

7.       We note your disclosure here and on pages 7, 38, and 46 that investors
   should not place
         undue reliance    on forward-looking statements in your registration
statement. Please
         revise these statements to remove any implication that investors are
not entitled to rely on
         disclosure in your registration statement.
Use of Proceeds, page 29

8.       We note that you plan to use approximately 50% of the net proceeds
from this offering for
         potential mergers and acquisitions. Please tell us whether there are
any current planned
         acquisitions and your consideration of whether they are probable.
Refer to Item 4b of Part
         I of Form F-1, which further refers to information required by Rule
3-05 and Article 11 of
 Raymond Wai Man Cheung
FirstName   LastNameRaymond  Wai Man Cheung
Basel Medical   Group Ltd
Comapany
April       NameBasel Medical Group Ltd
       15, 2024
April 315, 2024 Page 3
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FirstName LastName
         Regulation S-X. Please also note the disclosure requirements of Item
3B of Part I of Form
         20-F if net proceeds may or will be used to finance acquisitions of
other businesses.
9.       Please revise this section to provide more specific detail regarding
the use of the funds to
         be allocated to business expansion. See Item 3.C of Form 20-F.
Capitalization, page 31, page 31

10.      Pursuant to Item 3B of Part I of the Form 20-F, please also include
indebtedness in your
         Capitalization Table.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Review of Results of Operations, page 41

11.      We note the decrease in revenue was attributable to lower patient
count recorded for the
         clinics. Please revise your disclosure to describe the reason for the
lower patient count.
Industry Overview, page 46

12.      We note your disclosure on page 49 that the global sports medicine
market size was
         valued at $8,520 million in 2020 and is projected to reach $12,862
million by 2030. Please
         balance your disclosure by disclosing the total addressable market in
Singapore and the
         US that represents the types of sports medicine services that you
provide to your patients.
Business, page 52

13.      We note your disclosure on page 52 that your "clinics have been
selected by several
         insurance providers as preferred medical care providers and [y]our
clinics are mostly
         MediSave accredited," where your patients can submit their MediSave or
Integrated
         Shield Plan claims through your clinics. You also disclose that your
patients are either
         walk-in patients, employees of corporate clients or policyholders of
insurance companies.
         To provide context for investors about your business model and
operations, including the
         relevant risks, please disclose, for the financial periods presented,
the percentage of your
         revenue attributable to insurance payments compared to client
self-payments. Please also
         clarify whether you have entered into any long-term contracts with
insurance providers or
         payors, such as MediSave or Integrated Shield Plan, and if so, please
expand your
         disclosure to provide a brief description of the material terms of
such long-term contracts,
         including when you began accepting insurance payments from your
patients.
14.      We note your disclosure on pages 38 that you are    one of the top
medical specialist
         providers in Singapore    with an    established brand name    and
references on page 54 to
         your    best-in-class treatments and services    and    market-leading
position    on page 57.
         For all statements throughout the registration statement regarding
industry leadership,
         please substantiate your claims or remove such statements. In
addition, where you
         disclose on page 54 that you have a    deep bench of medical
practitioners,    please briefly
         describe how you measured and compared against other companies.
 Raymond Wai Man Cheung
FirstName   LastNameRaymond  Wai Man Cheung
Basel Medical   Group Ltd
Comapany
April       NameBasel Medical Group Ltd
       15, 2024
April 415, 2024 Page 4
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FirstName LastName
15.      We note your disclosure on page 46 and elsewhere in the registration
statement that the
         orthopedic market in Singapore is expected to be driven by key
factors, such as the aging
         population, and that elderly healthcare support has    always been one
of the main agenda
         of the Singapore government.    You also state on page 55 that your
Group is    strategically
         positioned    to meet this growing demand for musculoskeletal medical
services. Please
         expand your disclosure in this section to disclose the proportion of
your current patient
         database that constitute elderly patients.
We have a highly scalable corporate infrastructure..., page 54

16.      We note your disclosure on page 54 that    your shareholders bring
with them a strong
         global network    that provides access to capital, potential
partnerships, collaborations and
         market expansion opportunities on a global scale. Please clarify the
current status of
         discussions and negotiations regarding any partnerships or
collaborations. To the extent
         that negotiation regarding any such partnership or collaboration are
ongoing, please
         disclose material details of those processes and what relationships
you have to any such
         potential partners.
Our Growth Prospectus, page 55

17.      We note your disclosure on page 55 that the global orthopedic devices
market is projected
         to reach $48.1 billion by 2027 from $36.3 billion in 2022. Please
describe what is meant
         by    global orthopedic devices market,    clarify whether you develop
or manufacture any
         orthopedic devices, and expand your disclosure throughout the
registration statement to
         discuss the types of orthopedic devices that you provide. Please also
revise to include the
         addressable market for orthopedic treatments in Singapore and Asia,
including any
         orthopedic devices.
Our Business Model, page 57

18.      We note your disclosure on page 58 that your SKS and SKC group
entities are    currently
         dormant.    Please clarify whether these entities relate to Singapore
Knee, Sports and
         Orthopaedic Services Pte. Ltd. and Singapore Knee, Sports and
Orthopaedic Clinic Pte.
         Ltd., respectively, and if so, please provide additional detail
regarding the status of these
         entities, including the purpose for which the entities were created,
whether they conducted
         any operations to date, the scope of their activities, and why and
when they were closed
         and your future plans for these practices. Please revise your
disclosure elsewhere in the
         registration statement, including the organizational structures, as
applicable.
Our Corporate Clients, page 66

19.      We note your disclosure on page 54 and elsewhere in the registration
statement that your
         corporate client base underpins your business model and contributed
approximately 25%
         of your revenue in the fiscal year ended June 30, 2023. You also
disclose that 1,400
         patients were referred to by its corporate clients, 1,389 of which
were onboarded in the
 Raymond Wai Man Cheung
Basel Medical Group Ltd
April 15, 2024
Page 5
         last two fiscal years. Please expand your disclosure relating to your
corporate clients. By
         way of example only, please clarify whether your ten largest customers
include any of
         your corporate clients and address whether your business is dependent
on a concentrated
         number of corporate clients. Please revise to also include relevant
risk factor disclosure.
20.      You disclose that you have entered into arrangements with certain
corporate clients with
         perpetual terms, subject to periodic renewal or notice periods. Please
expand your
         disclosure relating to the long-term agreements you have entered into
and file such
         agreements as exhibits to the registration statement or provide us
with an analysis
         supporting a determination that you are not required to file them as
exhibits. See
         Instructions to Exhibits Section 4 of Form 20-F.
Our Medical Practitioners, page 66

21.      We note your disclosure relating to your four medical practitioners
credentials,
         experience and expertise. Please revise to disclose when each
practitioner joined your
         practice. We also refer to your disclosure on page 52 that your group
of medical
         practitioners consists of three orthopedic specialists and one
neurosurgery specialist.
         Please clarify whether each of the three orthopedic doctors provide
specific sub-specialties
         or services within the practice, which offers a range of orthopedic,
trauma, sports
         medicine treatments and services.
Competition, page 68

22.      We note your disclosure that there are certain other corporate groups
in Singapore offering
         orthopedic treatments, including listed companies, as well as small
and medium
         enterprises. Please revise to identify your key competitors and
clarify whether any of your
         competitors have also been offering similar private orthopedic and
physiotherapy services
         for twenty or more years in the Singapore market.
Our Patients and Clients, page 68

23.      Please expand your disclosure to provide a breakdown of your revenues
based on the type
         of services provided, such as sports medicine, trauma, and
neurosurgical services.
Intellectual Property, page 70

24.    We note your disclosure on page 7 that your business relies on the
recognition of [y]our
       brand names and trademarks    and that your intellectual property rights
primarily comprise
       of registered trademarks. Please revise to clarify whether you have
trademark protection
       for your brand names in each market in which you operate clinics and
expand your
FirstName LastNameRaymond Wai Man Cheung
       disclosure relating to your registered trademarks, including the number
of trademarks,
Comapany
       whenNameBasel
             you obtainedMedical  Group Ltd and the jurisdictions in which you
registered such
                            such trademarks,
       trademarks.
April 15, 2024 PagePlease
                      5    also revise your risk factor disclosure on page 13
accordingly.
FirstName LastName
 Raymond Wai Man Cheung
FirstName   LastNameRaymond  Wai Man Cheung
Basel Medical   Group Ltd
Comapany
April       NameBasel Medical Group Ltd
       15, 2024
April 615, 2024 Page 6
Page
FirstName LastName
Properties, page 70

25.      We note your disclosure on page 83 relating to your lease agreement
with Kevin Yip that
         expires on June 30, 2024 and a premises sharing agreement dated July
1, 2023 with
         Joanna Lin Medical Services Pte. Ltd. We also refer to the Tenancy
Agreement you
         entered into with Chan Orthopaedic Clinic Pte Ltd. that expires on
August 17, 2024 filed
         as Exhibit 10.12 to the registration statement. Please revise your
disclosure in this section
         to disclose the key terms of each agreement and disclose whether you
plan to renew such
         agreements, as applicable. Please also file the premises sharing
agreement with Joanna
         Lin Medical Services Pte. Ltd. as an exhibit to the registration
statement or explain to us
         why you are not required to do so. See Instructions to Exhibits
Section 4(b)(iv) of Form
         20-F.
Licenses, Permits and Approvals, page 71

26.      We note that three of your licenses for non-ionizing and ionizing
radiation irradiating
         apparatuses are expiring in 2024. Please clarify the status of such
licenses, including the
         expiration date for each such license. Please discuss the impact on
your business of such
         expiry and/or pending expiry of the licenses.
Directors and Executive Officers, page 76

27.      For each of Raymond Wai Man Cheung and Jianing Lu, please disclose the
specific skills,
         qualifications and attributes that led you to the conclusion that such
person should serve as
         your director. Refer to Item 6.A. of Form 20-F.
Employment Agreements and Director Agreements, page 77

28.      We note your disclosure that you have entered in employment agreement
with each of
         your executive officers. Please expand your disclose to include a
summary of the material
         terms of these agreements. Please also file the agreements as exhibits
to the registration
         statement or tell us why you believe you are not required to do so.
Refer to Instructions to
         Exhibits Section 4(c) of Form 20-F.
U.S. Federal Income Tax Considerations, page 97

29.      Please revise the heading of this section as well as the introductory
paragraph to clarify
         that the discussion is of the material tax consequences. Please refer
to Section III.C.1 of
         Staff Legal Bulletin No. 19 for guidance.
Consolidated Financial Statements
Consolidated Statement of Profit or Loss and Comprehensive Income, page F-3

30.      Your presentation of gross profit appears to exclude costs that you
would be required to
         incur in order to generate revenue. Your disclosure on page 40
indicates that these
         excluded costs include staff-related expenses (including remuneration
of doctors, nurses,
 Raymond Wai Man Cheung
FirstName   LastNameRaymond  Wai Man Cheung
Basel Medical   Group Ltd
Comapany
April       NameBasel Medical Group Ltd
       15, 2024
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         clinic assistants, physiotherapists and administrative staff),
premises-related expenses
         (including clinic rental and utilities), as well as depreciation and
amortization. It appears
         that your current presentation does not provide your financial
statement users insight into
         the total cost you incurred to generate your revenue or the amount
incurred for other
         functional activities, such as selling, general and administrative.
Please explain to us how
         you current presentation is appropriate under IAS 1, or make the
appropriate changes.
         Refer to paragraphs 15, 29, 85, 85A, 99, and 103 of IAS 1.

Note 2.4 Revenue, page F-11

31.      Pursuant to IFRS 15.119 (b), please disclose whether the consideration
amount is variable
         and whether the estimate of variable consideration is typically
constrained. For example,
         we note that there may be contractual adjustments and discounts
related to your
         arrangements with corporations and insurance which may result in
variable
         consideration.

32.      Please disclose the disaggregated revenue information required by IFRS
15.114 and also
         provide us your analysis of the disclosure requirements applied to
your full facts and
         circumstances.
33.      Please provide the disclosures required by IFRS 15.126 for determining
the transaction
         price and the amounts allocated to performance obligations.
Note 5. Other Income, page F-28, page F-28

34.      We note that other income derived from government grants represented
approximately
         13% of your profit before tax during the year ended June 30, 2022. In
this regard, please
         provide the disclosures required by IAS 20.39, including the nature of
government grants
         received and any unfulfilled conditions and contingencies related to
the government grants
         received.
Note 15. Amount Due From/(To) Related Parties, page F-34

35.      We note amount due from related parties of S$10.6 million represents
approximately 71%
         of your total current assets at June 30, 2023 and the amount due from
a director of S$1.3
         million represents an additional 9% of your total current assets. In
light of
         this significance, please provide more detailed disclosures regarding
these amounts,
         including the nature of the transactions which resulted in these
amounts due as well as the
         significant terms and conditions of these amounts due. Refer to IAS
24.18. Please also
         disclose whether any of these amounts have been subsequently collected
in cash.
Note 16. Borrowings, page F-35

36.      We note your disclosures pursuant to IFRS 7.18 regarding breaches of
covenants which
         resulted in the classification of certain term loans as current
liabilities. We also note the
 Raymond Wai Man Cheung
Basel Medical Group Ltd
April 15, 2024
Page 8
      maturity dates disclosed on page F-36. It appears that the amount
classified as current
      liabilities exceeds the amounts related to term loans with covenant
breaches and those
      with maturity dates within twelve months of the reporting period. In this
regard, please
      describe for us how you determined which bank borrowings should be
classified as
      current or noncurrent liabilities pursuant to IAS 1.69.
37.   In regards to your covenant breaches, please expand your disclosures to
address steps you
      are taking to avoid the breach, the impact or reasonably likely impact of
the breach
      (including the effects of any cross-default or cross-acceleration
provisions), and any
      alternate sources of funding to pay off resulting obligations or replace
funding.

Exhibits

38.   We note that certain portions of Exhibits 10.1 and 10.2 have been
redacted. Please revise
      the footnote to the exhibit index regarding the omission of information
from certain filed
      exhibits to specify the rule relied upon. Pursuant to Item
601(b)(10)(iv), please include a
      statement at the top of the first page of such exhibit stating that
certain information has
      been excluded because it is both not material and the type of information
that the
      registrant treats as private or confidential.
       Please contact Nudrat Salik at 202-551-3692 or Michael Fay at
202-551-3812 if you have
questions regarding comments on the financial statements and related matters.
Please contact
Robert Augustin at 202-551-8483 or Jane Park at 202-551-7439 with any other
questions.



                                                            Sincerely,

FirstName LastNameRaymond Wai Man Cheung                    Division of
Corporation Finance
                                                            Office of
Industrial Applications and
Comapany NameBasel Medical Group Ltd
                                                            Services
April 15, 2024 Page 8
cc:       Benjamin Tan, Esq.
FirstName LastName