March 9, 2020

Adriaan Davel
Chief Financial Officer
DRDGOLD LTD
1 Sixty Jan Smuts Building
2nd Floor-North Tower
160 Jan Smuts Avenue
Rosebank, 2196
South Africa

       Re: DRDGOLD LTD
           Form 20-F for the Fiscal Year ended June 30, 2019
           Filed October 31, 2019
           File No. 001-35387

Dear Mr. Davel:

        We have limited our review of your filing to the financial statements
and related
disclosures 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 comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 20-F for the Fiscal Year ended June 30, 2019

Financial Statements
Note 26 - Contingent Assets and Liabilities
Ekurhuleni Metropolitan Municipality ("Municipality") Electricity Tariff
Dispute, page 124

1.    We note you are currently engaged in a legal dispute with Ekurhuleni
Metropolitan
      Municipality (Municipality) relating to tariffs they have charged for
electricity supplied by
      ESKOM Holdings SOC Limited. We understand that in December of 2014 you
began
      depositing the disputed tariffs into a trust account rather than paying
the Municipality, and
      that this practice continued until January 2018, when you were required
to pay the tariffs
      held in arrears to the Municipality, in advance of settling the dispute.
Further, we note
      that in 2018 you began accounting for the disputed portion of the tariffs
differently, by
 Adriaan Davel
DRDGOLD LTD
March 9, 2020
Page 2
         recording the disputed portion of the payments as an asset on a
discounted basis.

         Please provide us with a roll-forward schedule covering each period
and all disputed
         tariffs to illustrate the effects of your accounting in the financial
statements. Please
         indicate the fiscal periods to which the amounts are attributable
according to the
         Municipality, as well as the expense recognized, extent of any
payments, amounts you are
         seeking to recover, and any provisions recognized in accordance with
IAS 37.

         Please reconcile these details with the information you have disclosed
in Notes 13, 22, 25
         and 26 of the financial statements and tell us how you considered
paragraphs 31 through
         35 of IAS 37 in recognizing the asset, Payments made under protest.
       In closing, 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.

       You may contact Mark Wojciechowski, Staff Accountant, at (202) 551-3759
or Jenifer
Gallagher, Staff Accountant, at (202) 551-3706 with any questions.



FirstName LastNameAdriaan Davel                               Sincerely,
Comapany NameDRDGOLD LTD
                                                              Division of
Corporation Finance
March 9, 2020 Page 2                                          Office of Energy
& Transportation
FirstName LastName