African Discovery : Attorney Letter regarding Current Information

John B. Lowy, P.C.

ATTORNEYS AT LAW

1345 Avenue of the Americas, 2d Floor

New York, New York 10105

Office [phone]

Mobile [phone]

John Lowy, Senior Partner*

*Licensed in NY and NJ

June 22, 2022

OTC Markets Group, Inc.

304 Hudson Street, Third Floor

New York, NY 10013

Re: African Discovery Group, Inc. ("AFDG")

Ladies and Gentlemen:

The undersigned law firm has been asked by African Discovery Group, Inc., a Nevada corporation (the "Issuer") to render this opinion as to whether the Issuer's Amended Annual Report for the fiscal year ended February 28, 2022, published by the Issuer on the OTC Disclosure & News Service on May 31, 2022 (the "Information"), constitutes adequate current information for purposes of Rule 144(c)(2) promulgated under the Securities Act of 1933 (the "Act"). The undersigned law firm represents the Issuer as securities counsel; its principal, John B. Lowy, owns beneficially or of record 28,671,102 shares of the Issuer's common stock (approximately 4.1% of the 705,284,953 issued and outstanding shares as of February 28, 2022). There is no agreement or understanding by which the law firm or its principal are to be issued any additional shares of the Issuer.

OTC Markets Group, Inc. ("OTC Markets") may rely on this opinion in determining whether the Issuer has made adequate current information publicly available within the meaning of Rule 144(c)(2) of the Act.

I have examined such corporate records and other documents obtained from public records, officers of the Issuer and other sources, and examined questions of law as I have deemed necessary or appropriate for purposes of rendering this opinion. As to matters of fact, I have made such inquiries of

the Issuer's officers as I deemed necessary to render this opinion, and I believe that all of the sources noted herein were reliable.

The person who prepared the financial statements of the Issuer contained in the Information is Mr. Fei Qi, who is qualified to prepare financial statements by virtue of being a CPA licensed in the State of New York, which authorizes him to also act as an accountant. The financial statements have not been audited.

The Issuer's transfer agent is West Coast Stock Transfer (the "Agent"). The Agent is registered with the SEC as such under the Securities Act. I have confirmed, with the Agent, the number of outstanding shares of the Issuer set forth in the Information.

The undersigned attorney has (a) personally met the CEO of the Issuer, namely Mr. Alan Kessler, and the CFO, namely Mr. Harry Green, (b) reviewed the Information posted by the Issuer on the OTC Disclosure & News Service, and (c) reviewed the posted Information with Messrs. Kessler, Green and Qi.

To my knowledge, after inquiry of management and the directors of the Issuer, the Issuer, no holder of five percent (5%) or more of its securities, nor the Issuer's counsel is currently under investigation by any federal or state regulatory authority for any violation of federal or state securities laws.

As a result of the foregoing, I am of the opinion that:

1. The Information constitutes adequate current public information concerning the Issuer's securities and the Issuer within the meaning of Rule 144(c)(2) under the Securities Act of 1933 (the "Act").
2. The Information is available within the meaning of Rule 144(c)(2).
3. The Information includes all of the information that a broker-dealer would be required to obtain from the Issuer to publish a quotation for the Issuer's securities under Rule 15c2-11 under the Exchange Act.
4. The Information complies as to form with the Pink OTC Markets Guidelines for Providing Adequate Current Information.
5. The Information has been posted through the OTC Disclosure & News Service.
6. Rule 144 ("Rule 144") under the Act, defines a "shell company" as a company which has no or nominal operations and either (i) no or nominal assets, (ii) assets consisting solely of cash and cash equivalents, or (iii) assets

consisting of any amount of cash and cash equivalents and nominal other assets). As of the date hereof, the Issuer is not a "shell company."

The undersigned attorney is a resident of the United States and is admitted to practice law in the States of New York and New Jersey. The undersigned attorney is not now, and for the past five years has not been, suspended or barred from practicing law in any state or other jurisdiction, or been charged in a civil or criminal case.

I am permitted to practice before the Securities and Exchange Commission (the "SEC") and have not been prohibited from practice thereunder. I am not currently, nor have I been in the past five years, the subject of an investigation, hearing, or proceeding by the SEC, the U.S Commodity Futures Trading Commission (CFTC), the Financial Industry Regulatory Authority (FINRA), or any other federal, state, or foreign regulatory agency.

This opinion is rendered solely to OTC Markets, and no person other than OTC Markets is entitled to rely upon it. However, OTC markets has full and complete permission and rights to publish this opinion through the OTC Disclosure & News Service, for viewing by the public and regulatory authorities.

This opinion is limited solely to the laws of the United States of America. This opinion speaks only of the above date and is based solely on the facts and circumstances known to me as of such date. In rendering this opinion, I assume no obligation to revise, update or supplement this opinion in response to any subsequent factual or legal developments.

Very truly yours,

/s/ John B. Lowy

John B. Lowy, P.C.