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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

June
18, 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. 6 to Registration
    Statement on Form F-1

    Filed June 3, 2024

    File No. 333-275956

Dear
Ms. Rivera:

We
represent Energys Group Limited (the “Company” or the “Registrant”) as U.S. counsel. We are filing herewith Amendment
7 to 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 June 14, 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 6 of the Company’s Registration Statement. For your convenience, the comments have been reproduced below,
followed by the Company’s response.

Amendment
No. 6 to Registration Statement on Form S-1 filed June 3, 2024

Exhibits

1. We
                                            note your revised legal opinion filed as Exhibit 5.1 to reflect the increased primary offering
                                            size. Please revise the legal opinion to cover the overallotment. In addition, please revise
                                            the fee table in Exhibit 107 to reflect the overallotment.

Response:

In
response to this comment, a Second Revised Opinion of Harney Westwood & Riegels regarding the validity of securities being registered
is being filed as Exhibit 5.1 to Amendment 7 to the Registration Statement and a Third Revised Filing Fee Table is being filed as Exhibit
107 to Amendment 7, both having been revised to include the shares subject to the over-allotment option.

Alternate
Pages for Resale Prospectus

The
Selling Shareholders, page Alt-2

2. Please
                                            clearly disclose whether Ms. Fung Ming Pang has any relationship with the company and its
                                            affiliates.

Response:

In
response to this comment, footnote (4) to the Selling Shareholders table on page Alt-2 has been revised to include that, other than as
a beneficial 5% shareholder, Ms. Pang is unrelated to the Company and its affiliates.

U.S.
Securities and Exchange Commission

June18,
2024

Page
2

3. Please
                                            reconcile the statement in your response letter dated May 10, 2024 that “(e)ach Selling
                                            Shareholder purchased his or her shares directly from a prior shareholder of the Registrant
                                            in a private transaction and the Registrant had no involvement in any of the sales”
                                            with the additional statement in the same response letter that “pursuant to a corporate
                                            reorganization in February 2023, Sky Shadow, Mr. Cox, Mr. Adams, Mr. Lee and Mr. To, collectively,
                                            transferred 100% of the issued and outstanding shares of EGHL to the Company in exchange
                                            for the issuance by the Company of 10,680,000 Ordinary Shares to Moonglade, 600,000 Ordinary
                                            Shares to Mr. Lee and 720,000 Ordinary Shares to Mr. To.”

Response:

The
Selling Shareholders - Jumbo Tiger Global Limited (“Jumbo”), Talent Linkage Limited (“Talent”) and Bright Forever
Investments Limited (“Bright”) - are the holders of record of the resale shares. Jumbo, Talent and Bright each acquired their
shares from their sole shareholders, Mr. Ka Lok To, Mr. Siu Chung Lee and Majestic Dragon Investment Co., Ltd. (which is wholly owned
by Ms. Fung Ming Pang), respectively.

Messrs.
To and Lee each acquired their shares in exchange for their shares of Energys Group Holding Limited (“EGHL”) as part of the
corporate reorganization that took place in February 2023. (Incidentally, Messrs. To and Lee had acquired their EGHL shares from Sky
Shadow Limited, which is wholly-owned by Mr. Michael Lau, in settlement of outstanding personal loans owed to them by Mr. Lau.) Accordingly,
there is no inconsistency between the two statements quoted in the comment because the statements pertain to the record owners of the
shares in question.

The
following table illustrates the chains of ownership of the various resale shares:

    Beneficial
    Owner
    Mr.
    To
    Mr.
    Lee
    Ms.
    Pang

    Selling

    Shareholder

    Jumbo(3)

    Talent(4)

    Bright(6)

    Majestic(6)

    Date
    Transferor

    Jan 31, 2023
    Sky Shadow
      6
                                              (1)

      5
                                              (1)

    Feb 23, 2023
    Company(2)
      720,000
                                              (3)
      0
      600,000
                                              (4)
      0
      0
      0

    Jan 30, 2024
    Mr To(5)
      (30,000
                                             )(4)
      0
      30,000
                                              (4)
      0
      0
      0

    Jan 30, 2024
    Mr.
                                 To(5) /Mr. Lee(5)

      (690,000 )
      690,000
                                              (5)
      (630,000 )
      630,000  (5)
      0
      0

    Feb 1, 2024
    Moonglade(5)
      0
      0
      0
      0
      680,000  (6)
      0

    Apr 24, 2024
    Majestic(5)
      0
      0
      0
      0
      (680,000 )
      680,000
                                              (6)

      690,000

      630,000

      680,000

 (1) Page
                                            62, On Jan 31, 2023, Mr. Lau caused Sky Shadow to transfer 5 shares (representing 5%) of
                                            EGHL owned of record by it to Mr. Siu Chung Lee and 6 shares (representing 6%) of EGHL owned
                                            of record by it to Mr. Ka Lok To in settlement of outstanding personal loans made by them to Mr. Lau.

 (2) Page
                                            61 & 62, The Reorganization

 (3) Page
                                            Alt-2, Note (3)

 (4) Page
                                            Alt-2, Note (7)

 (5) Page
                                            62 & 63, Recent Private Transfers

 (6) Page
                                            Alt-2, Notes (4) & (5)

The
fact that Messrs. To and Lee originally acquired the shares now owned of record by Jumbo and Talent, respectively, pursuant to the 2023
corporate reorganization does not contradict the fact that Jumbo and Talent acquired the shares from Mr. To and Mr. Lee. After the reorganization,
all of the recipients of Company shares were free to retain or dispose of the shares as they desired and to whomever they desired, with
no input or control by the Company.

We
do not dispute that Messrs. To and Lee, as the sole shareholders of Jumbo and Talent, respectively, remain the beneficial owners of the
shares. If our reply to comment #1 in our response letter of May 10, 2024 were revised to also discuss the beneficial ownership of the
shares, it would indicate that Messrs. To and Lee, the sole shareholders of Jumbo and Talent, respectively, are the beneficial owners
of the shares and that they acquired their shares of the Company as part of a corporate reorganization in February 2023. In addition,
the discussion under “Factor 1. How Long the Shares Have Been Held” would include the statement that Messrs. To and Lee,
the beneficial owners of the resale shares held of record by their wholly-owned entities, acquired the shares in February 2023.

U.S.
Securities and Exchange Commission

June18,
2024

Page
3

Plan
of Distribution, page Alt-3

4. We
                                            note your disclosure that your selling shareholders may sell their ordinary shares using
                                            any method permitted by applicable law. Please confirm your understanding that the retention
                                            by a selling shareholder of an underwriter would constitute a material change to your plan
                                            of distribution requiring a post-effective amendment. In addition, please revise to include
                                            the undertakings under Item 512 of Regulation S-K or tell us why it is not appropriate for
                                            you to do so. Refer to Item 9 of Form F-1.

Response:

Each
of the Selling Shareholders has represented to the Company that they have no intention to retain the services of an underwriter with
respect to the offer and sale of their shares. However, if, in the future, any Selling Shareholder decides to retain an underwriter,
we understand that such retention would constitute a material change to the plan of distribution requiring the Company to file a post-effective
amendment to the Registration Statement.

In
response to the second part of this comment, we have revised Item 9 of the Registration Statement to include all relevant undertakings
under Item 512 of Regulation S-K.

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.