SecProbe.io

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Mr John Hartz                                  Corus
Senior Assistant Chief Accountant              30 Millbank
United States                                  London SW1P 4WY
Securities and Exchange Commission             United Kingdom
100 F Street, NE                               Direct Tel  +44(0) 20 7717 4444
Washington, D.C. 20549-7010                    Direct Fax +44(0) 20 7717 4556
                                               Direct Fax +44(0) 20 7717 4643

09 September 2005

RE:      Corus Group plc
         Form 20-F for the fiscal year ended January 1, 2005
         Filed March 31, 2005

         File No. 1-10120

Dear Mr Hartz

I refer to your letter of August 2, 2005. We understand that the purpose of the
review process is to assist us in complying with the applicable disclosure
requirements and to enhance the overall disclosure of our filing, and we welcome
your contribution in this regard.

We have reviewed your comments (1) through to (14) and present below the
supplemental information you have requested. In addition, where appropriate, we
have indicated the approach we will adopt in future filings to address your
comments. For the convenience of the Staff each response has been numbered to
correspond with the comments in your letter.

In connection with our response I acknowledge that:
o    Corus Group plc is responsible for the adequacy and accuracy of the
     disclosure in its filings;
o    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; and
o    Corus Group plc may not assert Staff comments as a defence in any
     proceeding initiated by the Commission or any person under the federal
     securities laws of the United States.

Corus Group plc
Registered in England No. 3811373
Registered Office 30 Millbank
London SW1P 4WY

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Form 20-F for the fiscal year ended January 1, 2005
---------------------------------------------------

Aggregate contractual arrangements, page 30
-------------------------------------------
1. We note that your tabular debt maturity profile does not include the interest
commitments related to your debt. Include the interest commitments under your
interest-bearing debt in this table, or provide textual discussion of this
obligation in the footnotes to the table. If you provide a textual discussion,
the discussion should quantify the interest payments using the same time frames
stipulated in the table. Refer to footnote 46 to Release 33-8350.

1. We note the Staff's comment and footnote 46 of Release 33-8350. In future
filings we will include details of interest commitments within the table of debt
maturity profile. Below we have provided an example of our intended disclosure,
based on the values at January 1, 2005.

                                                         Payments due by period
                                                         ----------------------
<TABLE>
<CAPTION>

                                                    less than 1              1-3               3-5    greater than 5
                                   Total                   Year             Year              Year              Year
Contractual obligations       (pound) million   (pound) million  (pound) million   (pound) million   (pound) million
                              ---------------   ---------------   --------------   ---------------   ---------------
<S>                                    <C>                 <C>              <C>               <C>             <C>
Long term debt obligations             1,372                 5              360               295               712
Finance lease obligations                 41                 1                2                 2                36
Interest commitments                     639                93              184               141               221
Operating lease obligations              384                88              110                50               136
Purchase obligations                       -                 -                -                 -                 -
Other long term liabilities               26                 -                1                 -                25
                              ---------------   ---------------   --------------   ---------------   ---------------
Total                                  2,462               187              657               488             1,130
                              ===============   ===============   ==============   ===============   ===============

</TABLE>

The significant assumptions used in deriving the calculation of future interest
commitments are:
o    The calculation is based on debt obligations at the 2004 balance sheet
     date. Any change in the level of debt obligations in the future is not
     taken into account, except where existing debt becomes due for repayment,
     where it is assumed that this is not then replaced by new debt.
o    All existing obligations are held to their respective maturities.
o    Interest commitments denominated in foreign currencies are translated at
     the average rates for 2004 for those particular currencies.

Item 15 Controls and Procedures - Disclosure controls and procedures, page 46
-----------------------------------------------------------------------------
2. We note that your Chief Executive Officer and Chief Financial Officer
concluded your disclosure controls and procedures "... were effective in
providing reasonable assurance that the information required to be disclosed by
Corus in reports that it files under the US Exchange Act of

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1934, as amended, is recorded, processed, summarized and reported within the
time periods specified by the rules and the forms of the US Securities and
Exchange Commission." This is an incomplete definition of disclosure controls
and procedures per Rules 13a-15(e) and 15d-15(c) of the Exchange Act. Please
revise your disclosure to clarify, if true, that your officers concluded that
your disclosure controls and procedures are effective to ensure that information
required to be disclosed by you in the reports that you file or submit under the
Exchange Act is recorded, processed, summarized and reported, within the time
periods specified in the Commission's rules and forms and to ensure that
information required to be disclosed by an issuer in the reports that it files
or submits under the Exchange Act is accumulated and communicated to your
management, including its principal executive and principal financial officers,
or persons performing similar functions, as appropriate to allow timely
decisions regarding required disclosure. Otherwise, please simply conclude that
your disclosure controls and procedures are effective or ineffective, whichever
the case may be.

2. We note the Staff's comments and confirm our belief that our disclosure
controls and procedures are effective. In future filings we will extend the
nature of our disclosure in this regard to address the full definition of
disclosure controls and procedures under Rules 13a-15(e) and 15d-15(c) of the
Exchange Act.

Report & Accounts 2004
----------------------

Accounting policies, pages 50-51
--------------------------------
3. We note your belief that your accounting for provisions of retirement
benefits for employees, redundancy and rationalisation include areas of judgment
that relies upon a number of estimates and is subject to uncertainties. In
addition, we note that these areas of judgment can vary between different
countries in which the Group operates and there is a large degree of
inter-dependency between the countries, and as a result of these factors, no
analysis is given of a change in any one particular assumption. We believe that
this analysis is necessary for a reader's understanding of your critical
accounting policies. We believe your discussion of the fact that there are a
number of elements used in the assumptions, that they vary for the different
countries in which the Group operates and there may be inter-dependency between
some assumptions is a helpful reminder to readers that they should not view the
impact of a change in individual assumptions in isolation.

3. We believe that the disclosure of critical accounting estimates is a useful
aid to readers, to help identify and understand the most significant areas of
judgment applied by management in preparing the financial statements.

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In respect of retirement benefits we will seek to identify sensitivities in
respect of key assumptions in future filings. For example, we will expand our
disclosure to identify the following two significant sensitivities in relation
to the Group's main defined benefit pension scheme (the British Steel Pension
Scheme):
o    A 0.1% movement in the inflation or discount rate will change the estimate
     of scheme liabilities by +/-(pound)125m.
o    A 0.25% movement in the overall asset return assumption will change the
     pension cost by (pound)20m per annum.

The recognition and measurement of rationalisation and redundancy provisions
require management to seek both qualitative and quantitative information, and
advice from a number of different sources. The most difficult accounting aspect
is frequently whether or not the appropriate measurement criteria have been met
to determine if a provision should actually be made under GAAP and not the
calculation of the amount to be provided. Accordingly, there are few specific
assumptions made in the measurement of these provisions to which sensitivities
can be applied.

Presentation - II Basis of consolidation, page 89
-------------------------------------------------
4. We note your risk factor on page 3 of your Form 20-F that certain business
decisions concerning Corus Nederland requires the approval by the Corus
Nederland Supervisory Board, a body whose composition is not wholly within the
control of Corus and that this Supervisory Board has previously withheld its
approval of a key strategy decision of Corus Group. We also note that,
notwithstanding this Supervisory Board, Corus Nederland has been included in the
consolidated financial statements of Corus Group as a wholly owned subsidiary
consolidated under UK GAAP. Tell us what consideration you gave to the
appropriateness of consolidating this subsidiary under US GAAP given the
significant decisions that are subject to the Supervisory Board decisions. Refer
to SFAS 94.

4. In response to the Staff's comment we provide the following discussion of the
factors taken into consideration in order to conclude that Corus Nederland BV
(Corus Nederland) should be consolidated under both UK and US GAAP.

Under the Dutch statutory mitigated structure regime, Corus Nederland is
required to have a Supervisory Board to advise the Management Board. That
Supervisory Board is also responsible for supervising the policies of the
Management Board and the general course of business of the company. In
exercising its duties, the Supervisory Board must act in the best interests of
Corus Nederland and its business enterprise. Certain decisions of the Management
Board of Corus Nederland are reserved for approval by

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the Supervisory Board, including certain significant acquisitions and disposals.
The Supervisory Board may extend the decisions of the Management Board that are
subject to its approval and may suspend, but not appoint, members of the
Management Board.

The applicable accounting guidance in respect of consolidation rules under US
GAAP is SFAS 94 'Consolidation of all Majority Owned Subsidiaries'. As a general
rule SFAS 94 requires the consolidation of all companies where one company owns,
either directly or indirectly, over fifty percent of the outstanding voting
shares of another. The only exception to this rule should be where control does
not rest with the majority owner. On the basis that Corus Group plc owns 100% of
Corus Nederland there is a presumption under SFAS 94 that control exists and
this legal subsidiary should be wholly consolidated.

At this point it is necessary to consider whether other facts and circumstances
exist to suggest that this presumption is not valid. SFAS 94 provides examples
of circumstances where control may not rest with the majority owner; for
instance if the subsidiary is in legal reorganisation or in bankruptcy or
operates under foreign exchange restrictions, controls, or other governmentally
imposed uncertainties so severe that they may cast significant doubt on the
parent's ability to control the subsidiary. We do not believe that the existence
of the Dutch mitigated structure regime itself would constitute a severe
restriction. The Dutch subsidiary board structures and circumstances within
Corus are not unusual in this respect.

In addition, consideration needs to be given as to whether the existence of the
Supervisory Board and its rights clearly demonstrates that a parent company
cannot invoke appropriate control. If control is defined as the power to govern
the financial and operating policies of an entity then the existence of a
Supervisory Board does not preclude this power simply by its existence. In all
companies there are a variety of stakeholders including the shareholders,
customers, suppliers, employees (and their representatives) and, in the case of
the Dutch regime, the Supervisory Board. Specific to Corus, employees and their
representatives are required to be consulted on any restructuring programme. The
existence of the unions and the Works Councils does not permit the company to
embark on a restructuring programme without appropriate consultation; this
consultation process, for example, would not preclude consolidation of the
subsidiary. Although the level of consultation and influence exercised by the
Supervisory Board may in practice be greater than that of the unions, we believe
that the principle is similar in nature.

Notwithstanding the existence of the Supervisory Board, we also believe that the
managerial, operational and financial realities that bind Corus Group into a
single economic unit (a key factor for defining the limits of consolidation in
paragraph 30 of SFAS 94) are significantly stronger than the potential influence
of the mitigated structure regime. For example, there are now regular dividend
flows and loans of surplus cash from Corus Nederland to the parent company. Also
key-operating policies, such as the approval of capital

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expenditure, is undertaken by the board of Corus Group plc. Furthermore there
are common members between the board of Corus Group plc and the Supervisory
Board of Corus Nederland, and the operational management of the Group is based
on divisions that encompass operating locations across numerous legal entities
of the Group.

We would also like to advise the Staff that changes to the Dutch mitigated
structure regime were introduced with effect from October 1, 2004. These changes
provide, inter alia, that the Supervisory Board may nominate new members to the
Board, but that such appointments can only be made by the shareholder in general
meeting. The general meeting of shareholders will also have the power to
effectively dismiss the entire Supervisory Board. We believe that these new
powers reinforce our conclusion that Corus Group plc, as sole shareholder of
Corus Nederland, controls the underlying operations. Furthermore, changes in the
membership of the Supervisory Board have been announced by Corus during 2005.

In conclusion, it is our judgment that application of US GAAP to entities that
have investments in companies subject to the Dutch statutory mitigated structure
regime would not preclude consolidation of those investments. Both the legal
form (access to residual and ownership r