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DIGINEX
LIMITED

Smart-Space
Fintech 2, Room 3

Unit
401-404 Core C, Cyberport, Telegraph Bay,

Hong
Kong

    December
    20, 2024

VIA
EDGAR

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    RE:
    Diginex
    Limited (the “Company”)

    Registration
    Statement on Form F-1

    (File
    No. 333-282027) (the “Registration Statement”)

Ladies
and Gentlemen:

The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that such Registration Statement will become effective as of 4:30 p.m., Eastern Time, on December 20,
2024, or as soon thereafter as practicable.

The
Company hereby acknowledges that:

●
Should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority,
declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the
Registration Statement;

●
The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement;
and

●
The Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

If
there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461
of Regulation C. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel,
Loeb & Loeb LLP.

    Very
    truly yours,

    Diginex
    Limited

    By:
    /s/
    Miles Pelham

    Name:

    Miles
    Pelham

    Title:

    Chairman

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