March 7, 2025

Johan C. Kroner
Senior Vice President and Chief Financial Officer
Universal Corporation
9201 Forest Hill Avenue
Richmond, VA 23235

       Re: Universal Corporation
           Form 10-K for Fiscal Year Ended March 31, 2024
           File No. 001-00652
Dear Johan C. Kroner:

       We have reviewed your filing and have the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for Fiscal Year Ended March 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations, page 23

1.     Please revise to separately quantify each material factor that
contributed to the
       fluctuations in your results of operations. For example, you attribute
the increase in
       revenues for the Tobacco Operations segment during fiscal year 2024 to
higher
       tobacco sales prices and favorable product mix, partially offset by
lower tobacco sales
       volumes. You also attribute the higher selling, general and
administrative costs for
       fiscal year 2024 to higher incentive compensation costs, unfavorable
foreign currency
       comparisons, and costs related to a value-added tax settlement program
in Brazil.
       Refer to Item 303(b) of Regulation S-K.
        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.
 March 7, 2025
Page 2

       Please contact Valeria Franks at 202-551-7705 or Keira Nakada at
202-551-3659 with
any questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Trade &
Services