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 March 12, 2025

Greg Overholtzer
Chief Financial Officer
Trio Petroleum Corp.
5401 Business Park South, Suite 115
Bakersfield, California 93309

 Re: Trio Petroleum Corp.
 Form 10-K for Fiscal Year Ended October 31, 2024
 Filed January 17, 2025
 File No. 001-41643
Dear Greg Overholtzer:

 We have reviewed your filing and have the following comment(s).

 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 Fiscal Year Ended October 31, 2024
Business
Asphalt Ridge Option Agreement, page 3

1. Please revise your disclosure of billions of barrels of oil-in-place
 to clarify the
 reference is to an estimate for the entire Uinta Basin and does not
specifically refer to
 your Asphalt Ridge Development Project. Refer to the guidance
prohibiting disclosure
 of certain estimates of oil and gas resources other than reserves in the
Instruction to
 Item 1202 of Regulation S-K.

 You also note the estimate is derived from various independent
studies. Please
 identify the author or source of these studies and disclose the date
such studies were
 completed. This comment also applies to the disclosure on page 36.
South Salinas Project, page 5

2. To the extent there are known expirations or planned relinquishments of
material
 amounts of your undeveloped acreage in the aggregate over the near term
(3 5
 March 12, 2025
Page 2

 years), please expand your disclosure to provide the expiration dates
and the gross and
 net acreage amounts. Refer to the disclosure requirements in Item
1208(b) of
 Regulation S-K.
Evaluation of Reserves and Net Revenue, page 8

3. We note the discussion of technologies utilized by KLSP in their reserve
estimation
 efforts indicates the estimated reserves were prepared using analogs
conforming to the
 Society of Petroleum Engineers Petroleum Resource Management System (
 PRMS )
 definition. Refer to the disclosure requirements in Item 1201(c) of
Regulation S-K
 which specifies the definitions in Rule 4-10(a) of Regulation S-X shall
apply for
 purposes of disclosure under Subpart 229.1200 in the preparation of the
estimates of
 the probable and possible reserves disclosed in the reserves report and
in the filing on
 Form 10-K. Please revise or modify the discussion as necessary.
Disclosure of Reserve Volumes and Reserve Values as of the End of April 30,
2024, page 9

4. We note the statement SEC criteria stipulate that reserves cannot be
classified as P1
 Proved if said reserves are not fully permitted for long-term production
 appears
 inconsistent with the definition of reserves of all categories in Rule
4-10(a)(26) of
 Regulation S-K. Please explain to us in reasonable detail your rationale
for assigning
 probable and possible reserves without associated proved reserves.
General

5. Please confirm your understanding that we will not be in a position to
declare your
 Form S-1 effective until all outstanding comments regarding your Form
10-K for the
 fiscal year ended October 31, 2024 have been resolved. In addition, to
the extent that
 any comments related to our review of your Form 10-K apply to disclosure
in the
 Form S-1, please make corresponding revisions to all affected
disclosure.
 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 Sandra Wall at 202-551-4727 or John Hodgin at
202-551-3699 if you
have questions regarding the engineering comments. Please contact Brad Skinner,
Office
Chief, at 202-551-3489 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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