United States securities and exchange commission logo July 1, 2022 Mostafa Kandil Chief Executive Officer Swvl Holdings Corp The Offices 4, One Central Dubai World Trade Center Dubai, United Arab Emirates Re: Swvl Holdings Corp Amendment No. 2 to Registration Statement on Form F-1 Filed June 24, 2022 File No. 333-264418 Dear Mr. Kandil: We have reviewed your amended registration statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this comment, we may have additional comments. Amendment No. 2 to Registration Statement on Form F-1 Filed June 24, 2022 General 1. We note that paragraph 2.14 of the legal opinion filed as exhibit 5.1 assumes that the company is authorized to issue a certain number of shares, which is an impermissible assumption under Section II.B.3.a. of Staff Legal Bulletin No. 19. Please have counsel revise its opinion to remove this assumption. Mostafa Kandil FirstName LastNameMostafa Kandil Swvl Holdings Corp Comapany July 1, 2022NameSwvl Holdings Corp July 1,2 2022 Page 2 Page FirstName LastName Please contact Cara Wirth at (202) 551-7127 or Mara Ransom at (202) 551-3264 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Nicholas A. Dorsey