August 30, 2024

Mark Blick
Chief Executive Officer and Director
Diginex Ltd
Smart-Space Fintech 2, Room 3
Unit 401-404 Core C
Cyberport, Telegraph Bay
Hong Kong

       Re: Diginex Ltd
           Amendment No. 3 to Draft Registration Statement on Form F-1
           Submitted August 13, 2024
           CIK No. 0002010499
Dear Mark Blick:

     We have reviewed your amended draft registration statement and have the
following
comment.

        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.

Confidential Draft Registration Statement Filed on Form F-1 on August 13, 2024
Corporate History
The Restructuring, page 32

1.     Please given retroactive effect throughout the document to the
stock-split consummated
       on July 15, 2024.
       Please contact Joseph Kempf at 202-551-3352 or Robert Littlepage at
202-551-3361 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Matthew Crispino at 202-551-3456 or Jan Woo at 202-551-3453 with any
other
questions.
 August 30, 2024
Page 2



                  Sincerely,

                  Division of Corporation Finance
                  Office of Technology