December 6, 2024

Peter Rawlins
Chief Financial Officer
Premium Resources Ltd.
Suite 3400, One First Canadian Place
P. O. Box 130
Toronto, Ontario
Canada M5X1A4

       Re: Premium Resources Ltd.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Form 10-Q for Fiscal Quarter Ended September 30, 2024
           File No. 000-14740
Dear Peter Rawlins:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year Ended December 31, 2023
Item 2. Properties, page 13

1.     Please revise subsequent filings to include a map, or maps, showing the
location of all
       properties as required by Item 1303(b)(1) of Regulation S-K.
2.     Please revise subsequent filings to describe the internal controls used
in your
       exploration and mineral resource and reserve estimation efforts as
required by Item
       1305 of Regulation S-K.
Selected Financial Data, page 26

3.     We note you present a measure labelled as "Investment in exploration and
evaluation
       assets" in your selected financial data. Pease tell us why you have not
labelled this as
       a non-GAAP measure and provided the applicable disclosures under Item
10(e) of
       Regulation S-K. Please advise or revise your disclosures accordingly.
 December 6, 2024
Page 2

4.     Total assets and liabilities included in this table do not appear to
agree to the amounts
       presented in your financial statements. Please advise or revise your
disclosures as
       necessary.
Item 15. Exhibits, Financial Statement Schedules, page 60

5.     Please revise your technical report summaries to remove the historical
resource
       disclosure. All resource disclosure should be current and be prepared
under the S-K
       1300 definitions and requirements.
Form 10-Q for the quarter ended September 30, 2024
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Mineral Properties, page 35

6.     We note that you have disclosed mineral resources on page 35 of your
quarterly report
       that have not been prepared based on S-K 1300 reporting requirements.
Please revise
       to remove these estimates until prepared and reported in accordance with
S-K 1300,
       including the filing of a technical report summary pursuant to Item
1302(b)(2) of
       Regulation S-K.
        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 Joanna Lam at 202-551-3476 or Craig Arakawa at
202-551-3650 if you
have questions regarding comments on the financial statements and related
matters. Please
direct any questions to John Coleman at 202-551-3610 regarding the engineering
comments.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Energy &
Transportation