August 7, 2024

Loo See Yuen
Director
Bradbury Strategic Investment Fund A
The Center, Unit 5106-7 51st Floor
99 Queen's Road Central
Central, Hong Kong

       Re: Bradbury Strategic Investment Fund A
           IGC Pharma, Inc.
           Schedule 13D Filed by Bradbury Strategic Investment Fund A
           Filed May 21, 2024
           File No. 005-81669
Dear Loo See Yuen:

       We have reviewed the above-captioned filing and have the following
comments.

       Please respond to this letter by amending the filing or by providing the
requested
information. If you do not believe our comments apply to your facts and
circumstances or that an
amendment is appropriate, please advise us why in a response letter.

        After reviewing any amendment to the filing and any information
provided in response to
these comments, we may have additional comments. All defined terms used herein
have the same
meaning as in your filing, unless otherwise indicated.

Schedule 13D Filed May 21, 2024
General

1.     We note the date of the event reported as requiring the filing of the
Schedule 13D was
       March 22, 2024. Rule 13d-1(a) of Regulation 13D-G requires the filing of
a Schedule 13D
       within five business days after the date beneficial ownership of more
than five percent of
       a class of equity securities specified in Rule 13d-1(i)(1) was acquired.
Based on the
       March 22, 2024 event date, the Schedule 13D submitted on May 21, 2024
was not timely
       filed. Please advise us why the Schedule 13D was not filed within the
required five
       business days after the date of the acquisition.
2.     We note that the cover page of this Schedule 13D indicates that personal
funds were used
       to make the purchase of equity securities that precipitated the filing
of this Schedule 13D,
       whereas the disclosure offered in response to Item 3 of Schedule 13D
indicates that
 August 7, 2024
Page 2

       working capital was used instead. If personal funds were used, please
advise us, with a
       view toward revised disclosure, why a natural person was not identified
as a beneficial
       owner on a cover page within this filing or a filing made independent of
this one. Refer to
       Rule 13d-3(a) of Regulation 13D-G, which rule provision makes clear that
a beneficial
       owner includes any person who, directly or indirectly, through any
contract, arrangement,
       understanding, relationship, or otherwise has or shares voting or
investment power over a
       class of equity security specified in Rule 13d-1(i)(1). To the extent
that changes are made
       to reflect joint beneficial ownership over the securities for which
beneficial ownership has
       been reported in this filing, please be advised that additional changes
would need to be
       made to reflect that Bradbury Strategic Investment Fund A is not the
sole beneficial
       owner of the Shares reflected in this Schedule 13D.
Item 2, page 3

3.     Please amend this section to provide the information specified in Item 2
of Schedule 13D
       for each person specified in Instruction C within the "Special
Instructions for Complying
       With Schedule 13D" at Rule 13d-101 of Regulation 13D-G.
Item 5, page 4

4.     We note the disclosure offered in response to Item 5 that the 75,365,061
Shares
       outstanding as of April 18, 2024 used to calculate the reported
beneficial ownership
       percentage was based on the Issuer's Registration Statement on Form S-3
filed on April 4,
       2018. It does not appear that the Issuer filed a Registration Statement
on Form S-3 on that
       date, but that you instead meant to refer to the Form S-3 filed on April
18, 2024. Please
       revise or advise.
Item 6, page 4

5.     We note the Share Purchase Agreements included as exhibits to this
Schedule 13D have
       simply been referenced in the disclosure offered in response to Item 6
of Schedule 13D.
       As required by Item 6, please revise this section to provide a
description of these Share
       Purchase Agreements.
        We remind you that the filing person is responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

      Please direct any questions to Shane Callaghan at 202-551-6977 or
Nicholas Panos at
202-551-3266.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Mergers &
Acquisitions