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September 22, 2017

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-4238

Attention: Mr. Craig Arakawa, Accounting
Branch Chief Office of Beverages, Apparel and Mining.

Re: Mail Stop 3561, Caledonia
Mining Corporation Plc

Form 20-F for the Year Ended December
31, 2016

Filed March 30, 2017

File No. 000-13345

Dear Mr. Arakawa:

We have received your comment letter dated
August 25, 2017 regarding the Form 20-F for the Year Ended December 31, 2016 (the “Filing”) and provide our
responses to the Staff comments below. For ease of reference, we have repeated the Staff comments in italicized font type and followed
each comment with our response.

Response:

Financial Statements

Notes to the Consolidated Financial
Statements

4. Significant Accounting Policies

(e) Property Plant and Equipment
(iv) Depreciation, page F-14

1. You state on
note 3(a)(i) on page F-7 that in instances where management is able to demonstrate the economic recovery of such resources with
a high level of confidence, such additional resources, are included in the calculation of depreciation. To enhance our understanding
of your accounting policy, please:

 (a) Tell us the percentage and amount of measured, indicated and inferred resources that you include
in the calculation of depreciation.

The table below indicates the
percentage of each category of resources used in calculating depreciation in our Filing relating to the 2016 year:

Table A

    Category
    Tonnages
    Percentage

    Measured
    1 412 079
    19%

    Indicated
    3 334 828
    45%

    Inferred
    2 590 991
    36%

 (b) Tell us how you determined the economic recovery of the resources with a high level of confidence
to include in the calculation of depreciation. Please provide us with your history that demonstrates economic recovery of such
resources.

Blanket mine has been a producing
mine since about 1908. In addition, the current management has been in place for many years and has detailed knowledge of the Blanket
mineralisation:

 · The General Manager has worked on the mine for 46 years (starting in the resources department)
and has been general manager for 25 years;

Head Office:
Caledonia Mining Corporation Plc

3rd
floor, Weighbridge House, Weighbridge, St Helier, Jersey, Channel Islands, JE2 3NF

info@caledoniamining.com
| | www.caledoniamining.com

Directors:
Leigh Wilson (Chairman), Steve Curtis,

Johan Holtzhausen,
James Johnstone, Mark Learmonth, John Kelly, John McGloin

 · The Resource manager has been on staff for 17 years; and

 · A long history of defining resources by drilling and systematically developing and bringing the
resources into production has been established.

Blanket Mine adopted the Inclusive
method of reporting resources and reserves in 2014. Resources are reported inclusive of Reserves and hence the total of measured,
indicated and inferred resources includes 100% of the reported resource base of Blanket mine. However, when Caledonia acquired
Blanket mine in 2006, resources were reported exclusive of reserves. Since the greater portion of the historical data are available
in the exclusive format, resources calculated after 2014 are converted into the exclusive format to show conversion of resources
to reserves and production. The following table provides an analysis of the resource and reserve development for the period 2013
to 2015 with a breakdown of the factors responsible for the variations for each year.

Table B

    BLANKET MINE - ZIMBABWE

    Reconciliation of resource
    to reserve conversion for the years 2013 to 2015

    Year
    Resource
    Class Tonnes
    Reserve
    Class Tonnes
    Tonnes

    Inferred
    Indicated
    Probable
    Proven
    Pillars
    Milled

    2013
    2,871,098
    448,364
    2,304,811
    903,164
    766,883

    Net Change in Resources

    Tonnes added (-depleted)
    473,732
    290,915
    -440,738
    -30,221
    1,442
    -390,733

    new
    resource
    485,000
    290,000
    20,000
    30,000

    upgrade
    from
    -10,000
    -15,000
    -340,000

    5,000

    upgrade
    to

    10,000
    70,000
    213,000

    downgraded

    -30,000
    -50,000

    production

    -160,000
    -230,000

    -390,000

    2014
    3,344,830
    739,279
    1,864,073
    872,943
    768,325

    Net Change in Resources

    Tonnes added (-depleted)
    -753,840
    999,161
    -163,070
    -155,209
    8,119
    -440,082

    new
    resource
    340,000
    222,000

    15,000

    upgrade
    from
    -1,094,000
    -90,000
    -90,000

    10,000

    upgrade
    to

    930,000
    120,000
    80,000

    downgraded

    -70,000

     production

    -190,000
    -250,000

    -440,000

    2015
    2,590,991
    1,738,440
    1,701,003
    717,734
    776,444

Notes to the above table are
as follows:

 · “new resource” refers to resources previously unquantified. They are mainly inferred
but may also occur in the indicated, probable or measured classes depending on the level of information on the surrounding area;

 · “upgrade from” refers to depletion of the resource class when tonnes are upgraded to
a higher class while “upgrade to” refers to the blocks receiving the upgraded resource;

 · “production” refers to tonnages that have reported to the mill. Such tonnage may be
from depleted blocks or from blocks that are in the process of being upgraded and hence not included in the starting tonnage for
the year;

 · “downgraded” refers to resources that have been found to be below the pay limit and
therefore removed from the resource inventory. Downgrades can occur in all classes of resource or reserve. However, in the case
of inferred resources we have not experienced any significant downgrades.

 · Tonnages in reconciliation boxes are approximate/rounded to nearest 5000.

For the year December 2014 to
December 2015, a total of 1,094,000 tonnes of inferred resources was converted into 930,000 tonnes of indicated resources, a conversion
ratio of 85%. In addition 222,000 tonnes new resource was defined adjacent to an existing shoot and incorporated into the indicated
resource class. Together these upgrades represent an effective 105% resource conversion for the year. These blocks are undergoing
production development and production from them has already commenced.

    2

A longer term analysis in the
form of a chart which illustrates the resource growth of Blanket mine over the period 1994 to 2015 is also provided.

Notes:

 · arrows show the path of conversion of resources to reserves to production (milled tonnes);

 · the growth of resources over time illustrates that resources defined in earlier years are converted
to reserves and then to production.

Economic recovery

Economic recovery of inferred
resources is demonstrated by the achieved recovered grade relative to the mine’s pay limit for the period 2006 to 2015. The
pay limit has ranged from 2.3 g/t in 2008 to 1.9 g/t in 2014 while the recovered grade has ranged from 4.0 g/t to 3.3 g/t over
the period. All-in-sustaining-cost has remained consistently below the gold price received over this period resulting in economic
recovery of the inferred resources.

 (c) If inferred resources have been included, please separately address your history of economic
recovery of inferred resources. Please tell us your basis for their inclusion given that the tonnage, grade and mineral content
can typically only be estimated with a low level of confidence and explain to us how you compensated for this lower confidence
level.

Inferred resources have been
included as part of the denominator in the depreciation calculation. We believe a history of economic recovery is established as
illustrated in in section 1 (b).

We have included Inferred resources
as part of the denominator in the depreciation calculation as IAS 16 “Property, plant and equipment” defines
depreciation as the systematic allocation of the depreciable amount of an asset over its useful life and the useful life as:

(a) the period over which an
asset is expected to be available for use by an entity; or

(b) the number of production
or similar units expected to be obtained from the asset by an entity.

    3

Management believes the useful
life includes inferred resources for PP&E, depreciated over the life of mine. Inferred resources are included in the depreciation
calculation for these items because:

 · the orebodies at Blanket mine have an established history of conversion of inferred resources into
reserves or production units; and

 · the end depth of the Blanket mine orebodies has not been identified.

Due to the vertical nature of
the orebodies at Blanket mine it has not been economical or possible to obtain the quantity of diamond drilling results needed
to upgrade the inferred resources which are below 750 meters to a higher confidence category. Blanket mine is currently implementing
an investment plan (which is discussed further in the response to (d)) below) which is based on future production estimates
inclusive of inferred resources because there is as a history of converting inferred resources into reserves or production for
the orebodies where the end depth has not been determined. The investment plan at Blanket provides for, inter alia, the installation
of new infrastructure which will allow:

 · further exploration of existing inferred resources between 750 meters and 990 meters with the objective
of increasing the confidence level;

 · production from resources between 750 meters and 990 meters; and

 · further exploration below 990 meters.

This is evident from Table B
indicating 105% total conversion of inferred resources into indicated resources for the 2014-2015 period.

The Blanket mine ore systems
are known to be near vertical shoots along which gold has been introduced by hydrothermal fluids. These systems are typically enriched
in gold over considerable vertical intervals (500 – 2,000 meters), as evident at Vubachikwe, the adjoining mine to Blanket,
where ore shoots have been mined to 1500 meters depth. Diamond drilling at Blanket mine has established that the gold enrichment
interval persists on the major shoots to below the level currently planned for mining.

The end depth of orebodies has
not been identified through diamond drilling due to the vertical nature of the ore systems at Blanket mine. Full scale diamond
drilling has not commenced at these depths as it has either not been economical to drill this deep or underground development has
not allowed for angular diamond drilling at depth. Due to the nature of the vertical orebodies and the fact that the end of the
orebody at depth has not been established, enough confidence was placed by management to embark on investment plans to mine these
inferred orebodies prior to diamond drilling results converting these inferred resources to higher confidence categories.

The fact that the orebodies
continue at depth is further supported by an adjoining mine, mining at depths 1,500 meters plus. The average depth of inferred
resources at the Blanket mine is 900 meters.

 (d) Tell us the extent to which these resources are currently accessible and the extent to which
future capital improvements are required to convert and gain access to them. Please also tell us whether or not the future capital
improvements are included in your depletion computations and explain your rationale.

On November 3, 2014, Caledonia announced an investment plan (“Investment Plan”) and production projections for the Blanket
Mine. The objectives of the Investment Plan are to improve the underground infrastructure and logistics and allow an efficient
and sustainable production build-up.  The infrastructure improvements includes the continuation of the No. 6 Winze, the
development of a “Tramming Loop” and the sinking of a new 6-meter diameter Central Shaft from surface to 1,080 meters.

The increased
investment pursuant to the Investment Plan is expected to give rise to production from inferred resources of approximately
70,000  -- 75,000 ounces in 2021, this being in addition to projected production in 2021 from proven and probable mineral
reserves of approximately 6,000 ounces.

    4

The Investment Plan includes a life of mine plan for the Blanket Mine (the “LOM Plan”) in terms of which it is anticipated
that the approximate production from existing proven and probable mineral reserves above 750 meters level will be as set out
below.

    Approximate
    production from proven and probable mineral reserves above 750m (per LOM Plan)

    2017
    2018
    2019
    2020
    2021

    Tonnes
    milled (‘000)
    430
    380
    230
    100
    50

    Gold
    production (koz)
    43
    39
    23
    10
    6

The Central Shaft and the deepening
of No 6 winze will provide access to the current inferred mineral resources below 750 meters and allow for further exploration,
development and mining in these sections along the known Blanket strike, which is approximately 3 kilometers in length.  A
Preliminary Economic Assessment (“PEA”) was prepared in respect of the inferred mineral resources below 750 meters.
Based on the PEA, additional approximate production from current inferred mineral resources (excluding the projected production
set out above) is expected to be achieved in the following indicative ranges:

    Possible
    production from inferred mineral resources below 750m (per PEA)

    2017
    2018
    2019
    2020
    2021

    Tonnes
    milled (‘000)
    160
    215
    390
    550
    600

    Gold
    production (koz)
    20-22
    27-30
    46-50
    63-67
    70-75

The non-sustaining capital expenditure
relating to the Investment Plan amounted to $15,367,000 in fiscal 2016 (2015: $13,486,000; 2014: $ 3,833,000). Total capital expenditure
incurred up to December 31, 2016 is included in Property, plant and equipment (“PP&E”) and amounted to $19,159,000
(2015: $18,193,000; 2014: $ 7,166,000). Future capital expenditure is not included in our Filing as PP&E but this capital expenditure
in future periods will be included in PP&E as such expenditure is incurred.

PP&E improvements included
in our Filing are depreciated when it is in the location and condition necessary for it to be capable of operating in the manner
intended by management as required by IAS 16 “Property, plant and equipment”, par 55.

 (e) Provide us the amount of depletion expense for each producing mine with and without the inclusion
of inferred resources in the denominator for the year ended December 31, 2016 and the most recently reported 2017 interim period.

Caledonia Mining Corporation
Plc owns two gold mines, the Blanket gold mine situated in Zimbabwe and the Eersteling gold mine situated in South Africa. Blanket
gold mine is the only producing mine in the Caledonia Mining Plc group. The total depreciation expense of $3,491,000 in fiscal
2016 was made up of $3,733,000 of depreciation at the Blanket mine, $47,000 of depreciation at our South African office responsible
for procurement and the intercompany profit elimination of $289,000 as a result of sales made by our South African office to Blanket
mine. The Eersteling gold mine mining assets included in our Filing amounted to $225,335 at December 31, 2016. These items of PP&E
were not depreciated in fiscal 2016 as Eersteling was, and up to the date of this letter, remained on care and maintenance.

Depreciation of the PP&E
items at the Blanket mine, without inclusion of inferred resources as part of the denominator in the calculation, would have amounted
to $3,981,695 for fiscal 2016.

    5

Closing Comments

The Company acknowledges that it is responsible
for the adequacy and accuracy of the disclosure in the Filing, Staff comments or changes to disclosure in response to Staff comments
do not foreclose the Commission from taking any action with respect to the Filing, an