September 17, 2019

Warren Sheppard
Chief Executive Officer
Kibush Capital Corp.
2215-B Renaissance Drive
Las Vegas, NV 89119

       Re: Kibush Capital Corp.
           Amendment No. 1 to
           Registration Statement on Form S-1
           Filed September 12, 2019
           File No. 333-233066

Dear Mr. Sheppard:

      We have reviewed your amended registration statement and have the
following
comments. In some of our comments, 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 comments apply 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 these comments, we may have additional comments.



Amendment No. 1 to Form S-1 Filed September 12, 2019

General

1.     We note your disclosure that you do not have enough authorized shares to
complete the
       offering and that you intend to increase your authorized shares by
filing Articles of
       Amendment in Nevada. Please disclose whether you intend to comply with
the
       requirements of Schedule 14A for the increase in your authorized shares
prior to offering
       your shares.
 Warren Sheppard
Kibush Capital Corp.
September 17, 2019
Page 2
Related Party Transactions, page 36

2.    We note the amounts loaned to you from Mr. Sheppard in 2018 and 2019.
Please disclose
      largest aggregate amount of principal outstanding, the amount of
principal paid, the
      amount of interest paid and the interest payable on the loans. Refer to
Item 404(a)(5) of
      Regulation S-K. Additionally, please disclose the information required by
Item 404(c) for
      your promoters.
Condensed Consolidated Financial Statements, page 40

3.    Please update your financial statements to comply with Rule 8-08 of
Regulation S-X and
      provide corresponding updated disclosures throughout your filing.
Exhibits

4.    We note that the legal opinion currently opines on up to 250,000,000
shares of common
      stock. Please have legal counsel revise his legal opinion to cover all
the securities being
      offered.
Exhibit 23.2
Independent Registered Public Accounting Firm's Consent, page 1

5.    Your independent auditor's consent continues to refer to the audit report
dated February 8,
      2019 on your consolidated financial statements as of and for fiscal year
ended September
      30, 2018. However, we note that the audit report included on page F-21 of
your filing is
      dated February 4, 2019. Please have your independent auditor revise their
consent to
      correct the audit report date for fiscal year ended September 30, 2018.
       You may contact Suying Li at 202-551-3335 or Joel Parker at 202-551-3651
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Jonathan Burr at 202-551-5833 or Brigitte Lippmann at 202-551-3713 with any
other questions.



                                                            Sincerely,

FirstName LastNameWarren Sheppard                           Division of
Corporation Finance
                                                            Office of
Beverages, Apparel and
Comapany NameKibush Capital Corp.
                                                            Mining
September 17, 2019 Page 2
cc:       Matt Stout
FirstName LastName