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November 20, 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,

Caledonia Mining Corporation Plc (“the
Company”) has received your letter dated October 11, 2017 regarding the Form 20-F for the Year Ended December 31, 2016
(the “Filing”). In our reply we provide a brief background on how we came to our conclusion of depreciating over the
life-of-mine plan (“LoMP”) tonnages, inclusive of inferred resources. The background explanation is followed by our
responses to the Staff comments. For ease of reference, we have repeated the Staff comments in italicized font type and followed
each comment with our response.

Background:

Blanket Mine (“Blanket”) has
operated for over 100 years during which time, to the best of our knowledge, it never had resources to support a LoMP of more than
15 years. Blanket exploits several vertical ore bodies of which approximately 40% of our resource tonnages lie in the inferred
category. The limitations in upgrading our inferred resource, were due to:

 o The vertical nature of our ore bodies, which limits the depth to which we drill. Due to the steeply-dipping
nature of the ore bodies, to achieve a drill intersection that intersects the down dip targets below known mineralization would
require extended drill holes from surface, which would be both expensive and technically difficult. For practical purposes, we
explore the deeper levels from cross cuts at depth (currently 630 metres below surface and 750 metres below surface) from which
we drill to a depth of 300 to 500 metres below the cross-cut; and

 o The lack of infrastructure below 750 metres, giving access to inferred resources. Without the infrastructure
in place to extract the resources, inferred resources cannot be upgraded.

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,
Mark Learmonth, John Kelly, John McGloin

    1

Until recently, Blanket operated to a depth
of 750 metres below surface – it is only since fiscal 2015 that Blanket has begun to access deeper indicated resources below
750 metres. As at December 31, 2014, Blanket had reserves and indicated resources of 4.08 million tonnes, plus 3.35 million tonnes
of inferred resources of which 2.47 million tonnes was below 750 metres. In October 2014, recognizing that the ore above 750 metres
was rapidly being depleted, Blanket embarked on an investment programme of which the key element was the sinking of a new shaft
from surface to 1,080 metres. This investment programme was supported by a Preliminary Economic Analysis (“PEA”) which
was prepared on the basis that the known inferred resources at October 2014 would be exploited by the new shaft and related development.
From 2015 Blanket has also excavated horizontal cross cuts which allows us to increase our exploration activity below 750 metres.

In fiscal 2016 the investment plan showed
significant progress and the increased focus on deep drilling had resulted in large improvement upgrades from inferred resources.
This trend has continued with the announcement in early November 2017, of a further resource upgrade.

The changes to the limiting factors, a
history of conversion from inferred to higher resource or reserve categories and the conservative methods used in determining our
inferred resources supported the decision to include a portion of our inferred resources identified, in our LoMP.

Management as a result viewed the inferred
resources included in the LoMP, along with higher categories of resources and reserves, as the most reliable economic benefit utilization
pattern over which to depreciate our property, plant and equipment items.

Response:

Financial Statements

Notes to the Consolidated Financial
Statements

4. Significant Accounting Policies

(e) Property Plant and Equipment

(iv) Depreciation, page F-14

 1. We note your response to comment 1. To help us further understand your basis for inclusion of
inferred resources in your computation of depreciation, please address the following:

 · Provide your historical rates of converting inferred resources to indicated resources for the
past five years and any interim periods in 2017, to the extent available and demonstrate your history of economic recovery of inferred
resources during the same period.

Table 1 provides a summary of the conversion
of inferred resources to indicated resources or reserves over the period 2009 to 2016. It also indicates the annual movements.

In summary,
over the 5 year period 2009 to 2016, a total of 1.95 million tonnes of inferred resources
was converted resulting in 1.76 million tonnes of indicated resource and 0.39 million tonnes of reserves. The combined converted
resource of 2.15 million tonnes represents a 110% conversion relative to the initial 1.95 million tonnes of inferred resource.

    2

Table 1 further indicates an increased
rate of conversion of inferred resources from 2015 and 2016. This was due to the increased focus on deep level exploration activity.

Table 1:

    BLANKET MINE - ZIMBABWE

    Blanket Mine producing claims

    Summary reconciliation of inferred resource conversion for the years 2009 to 2016

    Year Ending
    Inferred Resources
    Indicated Resources & Reserves
    % Converted

     Dec 2009
    Resource totals
    2,467,000

    Resource Increase/Decrease(-)
    1,297,000

    New Inferred Resources added
    3,248,000

    Resources upgraded from Inferred
    -1,951,000
    2,150,000
    110%

    Dec 2016
    Resource totals
    3,764,000

    Note: The calculation of percentage conversion includes, where appropriate, resources upgraded to indicated, probable and proven, some of which was derived from inferred blocks previously excluded and some from new ore body extensions.

    Blanket Mine producing claims

Reconciliation of inferred resource conversion for the years 2009 to 2016

    Year ending
    Inferred resources
    Indicated resources & reserves
    % Converted

     Dec 2009
    Inferred total
    2,467,000

    YoY Resource Increase/Decrease(-)
    -59,000

    New Inferred Resources added
    0

    Resources upgraded from Inferred
    -59,000
    108,000
    183%

     Dec 2010
    Inferred total
    2,408,000

    YoY Resource Increase/Decrease(-)
    -65,000

    New Inferred Resources added
                   -

    Resources upgraded from Inferred
    -65,000
                       -
    0%

    Dec 2011
    Inferred total
    2,343,000

    YoY Resource Increase/Decrease(-)
    -53,000

    New Inferred Resources added
                   -

    Resources upgraded from Inferred
    -53,000
    39,000
    74%

    Dec 2012
    Inferred total
    2,290,000

    YoY Resource Increase/Decrease(-)
    581,000

    New Inferred Resources added
    592,000

    Resources upgraded from Inferred
    -11,000
    94,000
    855%

    3

    Dec 2013
    Inferred total
    2,871,000

    YoY Resource Increase/Decrease(-)
    474,000

    New Inferred Resources added
    494,000

    Resources upgraded from Inferred
    -20,000
    84,000
    420%

    Dec 2014
    Inferred total
    3,345,000

    YoY Resource Increase/Decrease(-)
    -754,000

    New Inferred Resources added
    322,000

    Resources upgraded from Inferred
    -1,076,000
    1,119,000
    104%

    Dec 2015
    Inferred total
    2,591,000

    YoY Resource Increase/Decrease(-)
    1,173,000

    New Inferred Resources added
    1,840,000

    Resources upgraded from Inferred
    -667,000
    707,000
    106%

    Dec 2016
    Inferred total
    3,764,000

Note:  Year-end resource estimates are accurate to 3 significant
figures.

    No publically available resource and reserve upgrade up to Q3 of 2017.

    Tonnages in reconciliation boxes are rounded to nearest 1000.

    Conversion percentages can exceed 100% if, in addition to the converted inferred resources, new resource blocks, not currently in the inventory, are included in the converted indicated resources.

The Table 2 below indicates the profitability of the Company
over the last 5 years and interim periods of 2017.

Table 2:

    Q2

2017
    2016
    2015
    2014
    2013
    2012

    USD' 000

    Revenue
      31,933
      61,992
      48,977
      53,313
      63,217
      75,236

    Gross profit
      10,681
      23,942
      13,181
      18,543
      29,010
      40,923

    Net profit
      4,031
      11,085
      5,590
      5,946
      *(477)
      7,122

*  Net loss of $477,000 in 2013 is after an impairment charge of approximately $14
million in respect of an exploration project in Zambia that was unrelated to the Blanket. No revenues were included other than
that from the Blanket Mine producing claims.

 · Provide us the estimated annual conversion rate of inferred resources included in your LoMP
for the historical and future periods. Also, provide us the expected ultimate conversion rate for the total inferred resource included
in the LoMP.

Blanket Mine’s LoMP is a mining and
financial model, updated by management and approved by the Board of Directors annually. In the annual preparation of the LoMP inferred
resources are discarded and/or upgraded to indicated resources or reserves before mining commences.

    4

When a LoMP is updated no conversion factor
is included as the inferred resources have already been discounted by approximately 30% at the resource estimation stage of the
inferred resource. In addition the LoMP only includes the total inferred resource in respect of which we have planned infrastructure
and does not include all the inferred resources as disclosed in our resource and reserve estimates (NI 43-101). Approximately 65%
of inferred resources are included in the current LoMP.

We have assumed a 100% conversion rate
of inferred resources in our LoMP in the recent past and for future periods in our current LOMP.

In addition to the 100% conversion rate
assumed, it should be noted that:

 o Blanket mine has in its resource inventory 35% of the inferred resources that are not included
in the LoMP.

 o Blanket operates an on-going exploration drilling programme aimed at increasing the LoMP and this
program supplements Blanket’s inferred resources continually. As a result there will be an increasing inferred resource base.

 · Compare the amount of inferred resources planned to be mined to the amount of inferred resources
that you actually mined for the past five years and any interim periods in 2017, to the extent available.

While inferred resources are included in
the LoMP, they are never mined as such but scheduled for mining in future years which gives time for the inferred resources to
be upgraded to reserves before they are mined.

To the extent that inferred resources are
included in the LoMP, they are expressed as bulk tonnage sources (not sub-blocked into short term production goals). The sequential
sub-blocking of the resources to reserves and concomitant nomenclature changes renders a reconciliation of the mined out areas
with the original equivalents in the inferred resources a complex and poorly quantifiable exercise, particularly as data has not
been collected to substantiate such a calculation. At this time an estimate of the comparison required is considered impractical.

 · Tell us how you compute inferred resources including the estimation methodologies employed and
geologic data considered. Please include details such as drill hole spacing, the percentage of inferred resources interpolated
between drill holes versus extrapolated, and differences in confidence levels between the inferred versus indicated categories.

Historically Blanket used the technique
of polygonal blocking for the estimation of both inferred and indicated resources which are based essentially on drill-hole information.
This method was used until 2014/5 at which stage digital data capture had advanced to the point where digital estimation was possible
using Dassault Systeme’s Surpac software. The following extract from the ‘Blanket 2004 Reserve/Resource Report’
defines the limiting spatial parameters used in resource definition.

Inferred Resource:

Inferred Resource block boundaries are
taken to the following limits where no point within the block is greater than the specified distance from a sample point (drill-hole
pierce point):

 o 60 m on strike

 o 120 m on dip.

    5

Down dip continuity at two times strike
is taken from the established geometry of pay shoots in various Blanket ore bodies which have depths at least three to four times
maximum strike.

The following exceptions limit the distance
of a resource block boundary from a sample point:

 o Where the 60 m limit exceeds the strike confines of the pay shoot defined by existing
up-dip mining limits.

 o Where peripheral intersections suggest a significant thinning of the mineralized zone.

 o Where un-mineralized holes indicate termination of the mineralized zone. In this instance
the boundary is taken halfway between the mineralized and non-mineralized intercepts, with the restrictions of pay-shoot boundary
taking precedence.

 o Where projected geological features (e.g. dykes and faults) are likely to affect the
mineralized zone.

Indicated Resource:

Indicated Resource block boundaries are
taken to the following limits where no point within the block is greater than the specified distance from a sample point, with
exceptions listed below:

 o 30 m on strike

 o 60 m on dip.

The 30 m strike distance of a resource
block from a borehole intersection is reduced in the following situations:

 o Where the 30 m limit exceeds the strike confines of the ore shoot defined by the up-dip
mining limits.

 o Where peripheral intersections suggest a significant narrowing of the mineralized
zone.

 o Where un-mineralized holes indicate termination of the mineralized zone. In this instance
the boundary is taken halfway between the mineralized and non-mineralized intercepts, with the restrictions of pay shoot boundary-taking
precedence.

 o Where projected geological features (e.g. dykes and faults) are likely to affect the
mineralized zone.

Prior to 2014 resource blocks were orthogonal
with a vertical long axis while subsequent to 2014 new resource blocks are defined in terms of search ellipses with the same horizontal
and vertical extents but which have a 28% lesser area of influence (i.e. no corners). Where drill-hole spacing is such that intersection
points are closer than the maximum spacing for inferred resources:

 o Orthogonal shapes are reduced to polygons. These polygons were computed graphically
using a digital planimeter and applying a dip correction.

 o Ellipses are fused with neighbouring ellipses to the extent that the ellipses overlap
to yield a single 3DM. The 3DM is blocked on a 5m x 5m x 1m grid and all block grades are calculated seamlessly by inverse distance
squared method utilising all data within each search radius. The resultant block model is queried for the blocks that are included
within the limits of the consolidated orthogonal polygon.

    6

It is evident from the above quotation
that geological structures are taken into account in the estimation of resource limits and extents. Structures affecting the ore
shoots are steep and are well mapped and hence their effect on the resource tonnages can be estimated with reasonable confidence.

Maximum drill-hole spacing for both inferred
and indicated resources are provided in the above quotation from Blanket 2004