                                                                     Exhibit 5.1


                      [Conyers Dill & Pearman Letterhead]



3 October 2003


Bunge Limited
50 Main Street
White Plains
New York 10606
U.S.A.

Dear Sirs

Bunge Limited (the "Company")

We have acted as special legal counsel in Bermuda to the Company in connection
with a registration statement on form S-8 filed with the Securities and Exchange
Commission (the "Commission") on 3 October 2003 (the "Registration Statement",
which term does not include any other document or agreement whether or not
specifically referred to therein or attached as an exhibit or schedule thereto)
relating to the registration under the United States Securities Act of 1933, as
amended, (the "Securities Act") of 5,018,226 common shares, par value US$0.01
per share (the "Common Shares"), issuable pursuant to the Bunge Limited Equity
Incentive Plan, as Amended and Restated on 13 March 2003 (the "Plan", which term
does not include any other document or agreement whether or not specifically
referred to therein or attached as an exhibit or schedule thereto).

For the purposes of giving this opinion, we have examined copies of the
Registration Statement and the Plan. We have also reviewed the memorandum of
association and the bye-laws of the Company, each certified by the Assistant
Secretary of the Company on 1 October 2003, certified copies of extracts from
minutes of a meeting of the members of the Company held on 30 May 2003 and from
minutes of a meeting of the board of directors of the Company held on 13 and 14
March 2003 (together, the "Minutes"), a copy of a letter to the Company from the
Bermuda Monetary Authority dated 10 July 2001 granting permission for the issue
and transfer of the Company's shares, subject to the conditions set out therein
and such other documents and made such enquiries as to questions of law as we
have deemed necessary in order to render the opinion set forth below.

We have assumed (a) the genuineness and authenticity of all signatures and the
conformity to the originals of all copies (whether or not certified) of all
documents examined by us and the authenticity and completeness of the originals
from which such copies were taken, (b) that where a document has been examined
by us in draft form, it will be or has been executed and/or filed in the form of
that draft, and where a number of drafts of a document have been examined by us
all changes thereto have been marked or otherwise drawn to our attention, (c)
that there is no provision of the law of any jurisdiction, other than Bermuda,
which would have any implication in relation to the opinions

<PAGE>

Bunge Limited - S-8 opinion
3 October 2003
Page 2


expressed herein, (d) the accuracy and completeness of all factual
representations made in the Registration Statement and the Plan and other
documents reviewed by us, (e) that the resolutions contained in the Minutes
remain in full force and effect and have not been rescinded or amended, (f)
that, upon the issue of any Common Shares, the Company will receive
consideration equal to at least the par value thereof and the shares of the
Company will be listed on an appointed stock exchange as defined in the
Companies Act 1981 of Bermuda.

We have made no investigation of and express no opinion in relation to the laws
of any jurisdiction other than Bermuda. This opinion is to be governed by and
construed in accordance with the laws of Bermuda and is limited to and is given
on the basis of the current law and practice in Bermuda. This opinion is
addressed to the Company solely for the benefit of the Company and for the
purpose of the issuacne of the Comon Shares as described in the Registration
Statement and the Plan and is neither to be transmitted to any other person, or
relied upon by any other person or for any other purpose nor quoted nor referred
to in any public document nor filed with any governmental agency or person
withotu our prior written consent.

On the basis of, and subject to, the foregoing, we are of the opinion that:

1.  The Company is duly incorporated and existing under the laws of Bermuda in
    good standing (meaning solely that it has not failed to make any filing with
    any Bermuda government authority or to pay any Bermuda government fees or
    tax which would make it liable to be struck off the Register of Companies
    and thereby cease to exist under the laws of Bermuda).

2.  When issued and paid for in accordance with the terms of the Plan, the
    Common Shares will be validly issued, fully paid and non-assessable (which
    term means when used herein that no further sums are required to be paid by
    the holders thereof in connection with the issue of such shares).

We consent to the filing of this opinion as an exhibit to the Registration
Statement. In giving such consent, we do not hereby admit that we are in the
category of persons whose consent is required under Section 7 of the Securities
Act or the Rules and Regulations of the Commission promulgated thereunder.


Yours faithfully,
/s/ Conyers Dill & Pearman
CONYERS DILL & PEARMAN






