[AGRIARPORATION 21/F Tower B, Ping An IFC 1-3 Xinyuan South Road, Chaoyang District, Beijing 100027 Tel: +86 10 8438 1060 Fax: +86 10 8438 1003 April 5th, 2011 VIA EDGAR AND FACSIMILE Tia Jenkins Re:riarporation Dear Ms.Jenkins and Mr.Archfield: For ease of review, we have set forth below each of the numberedmments of the Staffs]

[Item5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57 1. We note from your response to comment one of our letter dated February17, 2011 that you do not believe the proposed divestiture of P3A was probable, because it was subject to approval by the audit committee. In Item7 of your]

[March 4th, 2011 VIA EDGAR AND FACSIMILE John Reynolds Re: Agria Corporation Dear Mr. Reynolds and Mr. Archfield: For ease of review, we have set forth below each of the numbered comments of the Staff’s letter and the Company’s responses thereto. Item 5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57 1. The Company advises]

[March 4th, 2011 VIA EDGAR AND FACSIMILE John Reynolds Re:riarporation Dear Mr.Reynolds and Mr.Archfield: For ease of review, we have set forth below each of the numberedmments of the Staffs letter and thempanys responses thereto. Item5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57]

[March 4th, 2011 VIA EDGAR AND FACSIMILE John Reynolds Re:riarporation Dear Mr.Reynolds and Mr.Archfield: For ease of review, we have set forth below each of the numberedmments of the Staffs letter and thempanys responses thereto. Item5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57]