United States securities and exchange commission logo

                 September 6, 2022

       Youssef Salem
       Chief Financial Officer
       Swvl Holdings Corp
       The Offices 4, One Central
       Dubai World Trade Center
       Dubai, United Arab Emirates

                                                        Re: Swvl Holdings Corp
Statement on Form F-1
                                                            Filed on August 29,
                                                            File No. 333-267144

       Dear Mr. Salem:

              This is to advise you that we have not reviewed and will not
review your registration

               Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you
       that the company and its management are responsible for the accuracy and
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

              Please contact Janice Adeloye at 202-551-3034 or Taylor Beech at
202-551-4515 with
       any questions.


                 Division of Corporation Finance

                 Office of Trade & Services