SecProbe.io

CORRESP
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SCHLUETER
& ASSOCIATES, P.C.

5655
SOUTH YOSEMITE STREET, SUITE 350

GREENWOOD
VILLAGE, CO 80111

TELEPHONE:
+1-303-292-3883

FACSIMILE:
+1-303-648-5663

Email:
hfs@schlueterintl.com

February
26, 2024

VIA
EDGAR

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Ms. Isabel Rivera

    Re:
    Energys
    Group Ltd.

    Amendment
    No. 1 to Registration Statement on Form F-1

    Filed
    February 6, 2024

    File
    No. 333-275956

Dear
Ms. Rivera:

We
represent Energys Group Ltd. (the “Company” or the “Registrant”) as U.S. counsel. We are filing herewith the
Company’s Registration Statement on Form F-1 relating to a proposed initial public offering in the United States of the Company’s
Ordinary Shares.

The
purpose of this letter is to respond to the comment letter dated February 20, 2024 from the Division of Corporation Finance, Office of
Real Estate and Construction (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission” or
“SEC”) relating to Amendment 1 of the Company’s Registration Statement. For your convenience, the comments have been
reproduced below, followed by the Company’s response.

Amendment
No. 1 to Registration Statement on Form F-1 filed February 6, 2024

Cover
Page

1. We
                                            note the disclosure that your offering of common shares will be at an “assumed”
                                            public offering price. Please tell us whether you plan to amend prior to effectiveness to
                                            include the final offering price as opposed to an “assumed” offering price.

Response:

Please
note that the assumed offering price of $5.00 per share has been changed in Amendment 2 to a range of $4.00 to $6.00 per share. When
a final offering price has been determined, the Registrant will file an Amendment to disclose that price.

U.S.
Securities and Exchange Commission

February 26, 2024

Page 2

Primary
Offering Prospectus, page 1

2. Please
                                            revise throughout to clearly disclose the selling shareholder offering that will occur following
                                            the IPO and listing on the Nasdaq Capital Market. Add risk factor disclosure regarding the
                                            impact the selling shareholder offering may have upon the market price. In addition, please
                                            reconcile the statement on page 120 that “any shares sold by the Selling Shareholders
                                            until our Ordinary Shares are listed or quoted on an established public trading market will
                                            take place at $5.00 per share” with the disclosure on the selling shareholder prospectus
                                            cover page that “no sales of the shares covered by this prospectus shall occur until
                                            the Ordinary Shares sold in our initial public offering begin trading on the Nasdaq Capital
                                            Market.”

Response:

In
response to this comment, disclosure has been added to the Prospectus on the cover page and on pages 7, 24 and 120, including an additional
risk factor regarding the impact registration of the Resale Shares may have upon the market price of the Ordinary Shares. (Supplementally,
please note that the number of Resale Shares has been reduced from 2,350,000 to 2,000,000 shares.)

In
addition, the disclosure on the cover page of the Resale Prospectus has been revised to correspond to the disclosure on page 120 of the
primary offering prospectus.

Exhibits

3. We
                                            note the addition of the amount of securities and offering price to the cover page. Please
                                            revise the exhibits fee table.

Response:

In
response to this comment, Exhibit 107, the Fee Table, has been revised to reflect the number of securities being offered and the offering
price.

Alternate
Page for Resale Prospectus

The
Selling Shareholders, page Alt-4

4. We
                                            note that the shares being registered for resale were recently purchased in the private transfers
                                            disclosed on page 2. Please revise to disclose the price at which such shares were purchased
                                            by the selling shareholders. Please also clarify the nature of any position, office, or other
                                            material relationship which the selling shareholder has had within the past three years with
                                            the registrant or any of its predecessors or affiliates, including the party from whom the
                                            shares were purchased.

Response:

In
response to this comment, the Registrant has added disclosure to page Alt-2 of the Resale Prospectus and also to page 2 of the Public
Prospectus containing the price paid by each Selling Shareholder for its shares, the identities of the sellers and the nature
of any relationship between the Selling Shareholders and the Registrant, its affiliates and the sellers of the shares.

Supplementally, the Registrant notes
that Moonglade, which is controlled by Messrs. Cox and Lau, was willing to sell the shares to Majestic Dragon Investment Co. Limited
and Vibrant Sound Limited at a discount from the assumed initial public offering price. With respect to the Majestic Dragon sale, registration
of the shares for resale would increase the public float and thereby enable the Company to satisfy the listing requirements of the Nasdaq
Capital Market. Please also note that Mr. To's sale of shares to Mr. Lee was at the same price that Mr. To paid for the shares.

U.S.
Securities and Exchange Commission

February 26, 2024

Page 3

If
you have any questions relating to the Registration Statement, please contact Kevin Cox, the Registrant’s Chief Executive Officer,
at his email address of kevin.cox@energysgroup.com, or Michael Lau, the Registrant’s Chief Technical Officer, at his email
address of michael.lau@energysgroup.com.

Please
copy any correspondence or requests for information to the undersigned and Celia Velletri. The undersigned’s email is set forth
above, and Ms. Velletri’s email is cv@schlueterintl.com. If you wish to speak with us, please feel free to call me at 303-292-3883
or Celia Velletri at 303-907-4842.

    Very
    truly yours,

    /s/
    Henry F. Schlueter

    Henry
    F. Schlueter

    C:

    Energys
    Group Ltd.

    WWC,
    P.C.