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Basel
Medical Group Ltd

6
Napier Road,

Unit
#02-10/11 Gleneagles Medical Centre

Singapore
258499

Date:
September 13, 2024

Via
EDGAR

Division
of Corporation Finance

Office
of Energy & Transportation

U.S.
Securities and Exchange Commission

Washington,
D.C. 20549

    Attn.:
    Nudrat
    Salik

    Michael
    Fay

    Robert
    Augustin

    Jane
    Park

    Re:
    Basel
    Medical Group Ltd

    Amendment
    No. 4 to Draft Registration Statement on Form F-1

    Submitted
    August 29, 2024

    CIK
    No. 0002004489

Ladies
and Gentlemen:

Basel
Medical Group Ltd (the “Company”) hereby submits to the staff (the “Staff”) of the U.S. Securities
and Exchanges Commission (the “Commission”) this letter setting forth responses to the comments contained in the Staff’s
letter dated September 10, 2024 on the Company’s Draft Registration Statement on Form F-1 previously submitted on August 29, 2024.

Concurrently
with the filing of this letter, the Company is publicly filing its registration statement on Form F-1 (the “Registration
Statement”) with the Commission.

The
Staff’s comments are repeated below in bold and are followed by our responses. We have included page references in the Registration
Statement where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the
meanings set forth in the Registration Statement.

Amendment
No. 4 to Draft Registration Statement on Form F-1 submitted August 29, 2024

Related
Party Transactions, page 84

    1.
    As
    it relates to the August 23, 2024 deed of undertaking, please disclose (i) the date on which Rainforest Capital VCC made its payment
    to Basel Medical in satisfaction of amounts owed by Singmed Investment Pte Ltd and Dr. Yip to Basel Medical and (ii) the actual payment
    amount. In addition, for the periods presented through the date of payment by Rainforest Capital VCC, please disclose a rollforward
    of the amounts due to and from Singmed Investment Pte Ltd, Dr. Yip and Basel Medical.

Response:
Pursuant to the Deed of Undertaking between Rainforest Capital VCC and Basel Medical dated August 23, 2024 (the “Repayment
Deed”), Rainforest Capital VCC undertook to fully transfer and pay to Basel Medical, any and all outstanding receivables owed by
Singmed Investment Pte Ltd (“SMI”) and Dr Kevin Yip to Basel Medical and/or its subsidiaries (collectively the
“Group”), being S$11,877,624, to Basel Medical by the end of September 2024.

Please
refer to the table below for the original amount due from Dr. Kevin Yip and amount due from related parties as of June 30, 2023
(the “Loan Amount”). Pursuant to the Deed of Undertaking between certain Group entities and Singmed Investment Pte.
Ltd. dated August 26, 2024, the Group’s subsidiaries have agreed to waive the interest on the Loan Amount from July 1, 2023 onwards.
Hence, the Loan Amount has not increased since June 30, 2023.

    Applicable

                                                                               Amounts

(US$)

    Applicable Dates

    Amount due from Dr Kevin Yip
      976,453
    As of June 30, 2023

    Amount
    due from SMI
      7,806,823
    As of June 30, 2023

    Total amount due from Dr Kevin Yip/SMI as of June 30, 2023
      8,783,276
    As of June 30, 2023

    Professional medical practice salaries owed to Dr Kevin Yip by Basel Medical (offset
    against amount due from Dr Kevin Yip)
      (682,180)
    From July 1, 2023 to June 30, 2024

    Professional fees for this offering paid by Rainforest Capital VCC on behalf of Basel Medical
    Group Ltd as of June 30, 2024 (offset against amounts due)
      (599,730)
    From July 12, 2023 to June 30, 2024

    Cash repayments from Rainforest Capital VCC and a shareholder of Rainforest Capital VCC to the
    Group

    Cash repayment
      (20,000)
    February 27, 2024

    Cash repayment
      (630,000)
    July 22, 2024

    Cash repayment
      (4,048,000)
    July 31, 2024

    Cash repayment
      (750,000)
    August 15, 2024

    Cash repayment
      (750,000)
    August 16, 2024

    Total repayment by Rainforest Capital VCC and its related
    party and other offset amounts
      (7,479,910)

    Remaining amount due from Dr Kevin Yip /SMI as of September
    12, 2024
      1,303,366
    Payable by the end of September 2024

Following
the repayment of the sums set out above to Basel Medical’s Group entities, a final sum of US$1,303,366 remains due to Basel Medical,
and in accordance with the terms of the Repayment Deed, such sum will be repaid to Basel Medical by Rainforest Capital VCC
 by the end of September 2024.

Kindly
address any comments or questions that you have concerning this letter or the draft submission to our attorneys Benjamin Tan Esq. and
Martryn Mak Esq. of Sichenzia Ross Ference Carmel LLP at (646) 810-0609 or btan@srfc.law and (646) 963-6393 or mmak@srfc.law.

Thank
you for your time and attention.

    Very
    truly yours,

    For
and on behalf of Basel Medical Group Ltd

    /s/ Raymond Wai Man Cheung

    Name:
    Raymond
    Wai Man Cheung

    Position:
    Chief
    Executive Officer