<DOCUMENT>
<TYPE>EX-5
<SEQUENCE>2
<FILENAME>d500664_ex5-1.txt
<DESCRIPTION>EX 5.1
<TEXT>
                              [Letterhead omitted]


Nordic American Tanker Shipping
Limited
Canon's Court
22 Victoria Street
Hamilton HM 12
Bermuda




                                                                 11 August 2004

Ladies and Gentlemen,

     Nordic American Tanker  Shipping  Limited - Registration  Statement on Form
     S-3 Filing

     We have acted as legal  advisers  as to  matters  of Bermuda  law to Nordic
     American Tanker Shipping Limited, a company organized under the laws of the
     Islands of Bermuda (the "Company") and in such capacity we have assisted in
     the preparation and filing with the Securities and Exchange Commission (the
     "Commission") under the Securities Act of 1933, as amended (the "Securities
     Act"), of a Registration Statement on Form F-3 (such registration statement
     and any additional  registration statement filed pursuant to Rule 462(b) is
     referred to as the "Registration Statement") in respect of the contemplated
     issuance by the Company from time to time of up to  $500,000,000  aggregate
     public offering price (or any such further  aggregate public offering price
     as may be registered  pursuant to Rule 462(b)) or the equivalent thereof in
     one or more foreign currencies,  currency units or composite  currencies of
     (i) senior debt securities and subordinated  debt securities  (collectively
     referred  to as the "Debt  Securities"),  which may be issued  pursuant  to
     separate indentures,  as amended or supplemented from time to time, between
     the  Company  and the  trustee  named  in the  applicable  indenture;  (ii)
     preferred shares in the Company (the "Preferred  Stock");  and (iii) common
     shares in the Company,  par value $0.01 per share (the "Common Stock"). The
     Debt Securities, Preferred Stock and Common Stock are hereafter referred to
     as the "Securities" and each a "Security".

     For the  purposes  of this  opinion we have  examined  and relied  upon the
     documents listed (which in some cases, are also defined) in the Schedule to
     this opinion (the "Documents").

     Assumptions

     In stating our opinion we have assumed:

     (a)  the authenticity, accuracy and completeness of all Documents submitted
          to us as originals and the conformity to authentic  original Documents
          of all Documents submitted to us as certified, conformed, notarised or
          photostatic copies;

     (b)  the genuineness of all signatures on the Documents;

     (c)  the authority, capacity and power of persons signing the Documents;

     (d)  that any  representation,  warranty or statement of fact or law, other
          than  the  laws of  Bermuda  made in any of the  Documents,  is  true,
          accurate and complete;

     (e)  that  there  are no  provisions  of the  laws  or  regulations  of any
          jurisdiction  other than Bermuda which would have any  implication  in
          relation to the opinions expressed herein;

     (f)  that  there  are no  provisions  of the  laws  or  regulations  of any
          jurisdiction  other than  Bermuda  which would be  contravened  by any
          actions  taken by the  Company  in  connection  with the  Registration
          Statement  or which  would have any  implication  in  relation  to the
          opinion  expressed herein and that, in so far as any obligation under,
          or action to be taken under, the Registration Statement is required to
          be  performed  or  taken  in any  jurisdiction  outside  Bermuda,  the
          performance  of such  obligation  or the  taking of such  action  will
          constitute  a valid  and  binding  obligation  of each of the  parties
          thereto under the laws of that jurisdiction and will not be illegal by
          virtue of the laws of that jurisdiction;

     (g)  that no litigation,  administrative  or other  proceeding of or before
          any governmental  authority of Bermuda is pending against or affecting
          the Company;  (ii) that no notice to the Registrar of Companies of the
          passing of a  resolution  of members  or  creditors  to wind up or the
          appointment  of a liquidator or receiver has been given to petition to
          wind up the Company;  and (ii) that no  application  to reorganise the
          affairs  of  the  Company  pursuant  to a  scheme  of  arrangement  or
          application  for the appointment of a receiver has been filed with the
          Supreme Court;

     (h)  that the Debt  Securities,  and any indentures or other  agreements in
          connection  therewith  will  effect and  constitute  legal,  valid and
          binding  obligations  of each of the parties  thereto,  enforceable in
          accordance  with their terms,  under the laws of the  jurisdiction  by
          which they are expressed to be governed; and

     (i)  that, when the Preferred Stock and Common Stock are issued,  the issue
          price (in  whatever  form) would not be less than the par value of the
          Preferred  Stock and Common Stock and the Company will have sufficient
          authorised but unissued share capital to effect the issue.

     Opinion

     Based upon and subject to the foregoing and subject to the reservations set
     out below and to any  matters  not  disclosed  to us, we are of the opinion
     that:

     (1)  Upon the fixing of the designations,  relative rights, preferences and
          limitations of any series of Preferred Stock by the Board of Directors
          of the Company with the sanction of a shareholders  resolution and the
          establishment of such series of Preferred Stock and the number of such
          Preferred  Stock to be issued,  all in  conformity  with the Company's
          Memorandum of Association  and the Bye-Laws,  upon the approval of the
          Board  of  Directors  of the  Company  of the  specific  terms  of the
          issuance,  all necessary  corporate  action on the part of the Company
          will have been taken to authorize the issuance and sale of such series
          of Preferred  Stock proposed to be sold by the Company,  and when such
          Preferred Stocks are issued and delivered  against payment therefor in
          accordance  with  the  applicable  agreement  or  upon  conversion  or
          exchange in accordance  with the terms of any other  Security that has
          been duly authorized,  issued, paid for and delivered,  such Preferred
          Stock will be validly issued, fully paid and non-assessable.

     (2)  The shares of Common  Stock,  when the terms of the  issuance and sale
          thereof  have been duly  approved  by the  Board of  Directors  of the
          Company in conformity with the Company's Memorandum of Association and
          Bye-Laws  when  issued  and  delivered  against  payment  therefor  in
          accordance  with  the  applicable  agreement  or  upon  conversion  or
          exchange of any Security that has been duly authorized,  issued,  paid
          for  and   delivered,   will  be  validly   issued,   fully  paid  and
          non-assessable.

     (3)  When the specific  terms of a particular  Debt Security have been duly
          authorized by the Board of Directors of the Company and established in
          accordance  with the  applicable  indenture and such Debt Security has
          been duly executed,  authenticated,  issued for value and delivered in
          accordance with the applicable indenture, such Debt Security will be a
          binding obligation of the Company,  enforceable against the Company in
          accordance with its terms,  except as enforceability may be limited by
          bankruptcy, insolvency, reorganization, fraudulent conveyance or other
          laws relating to or affecting  creditors' rights generally and subject
          to general principles of equity,  including  application by a court of
          competent  jurisdiction  of  principles  of good faith,  fair dealing,
          commercial reasonableness, materiality, unconscionability and conflict
          with public policy or other similar principles.

     (4)  Subject as otherwise provided in this opinion,  and except as provided
          in this paragraph,  no consent,  licence or  authorisation  of, filing
          with, or other act by or in respect of, any governmental  authority or
          court  of  Bermuda  is  required  to be  obtained  by the  Company  in
          connection with the issuance of the Securities except that:

          (i)  the permission of the Bermuda Monetary  Authority is required and
               letters of  permission  has not yet been  sought for the issue of
               any of the Securities of the Company; and

          (ii) the Registration  Statement and any other offering documents must
               be filed with the  Registrar  of  Companies  and  comply,  to the
               extent  applicable,  with  the  requirements  of Part  III of the
               Companies Act 1981 prior to or as soon as reasonably  practicable
               after any Securities are offered to the public.

     Reservations

     We have the following reservations:

     (a)  We express no opinion as to any law other than Bermuda law and none of
          the opinions  expressed  herein relates to compliance  with or matters
          governed by the laws of any jurisdiction except Bermuda.  This opinion
          is limited  to Bermuda  law as applied by the courts of Bermuda at the
          date hereof.

     (b)  Where an  obligation is to be performed in a  jurisdiction  other than
          Bermuda,  the courts of Bermuda may refuse to enforce it to the extent
          that such performance  would be illegal under the laws of, or contrary
          to public policy of, such other jurisdiction.

     (c)  Where a person is vested with  discretion or may determine a matter in
          his  or  its  opinion,  such  discretion  may  have  to  be  exercised
          reasonably  or such an  opinion  may have to be  based  on  reasonable
          grounds.

     (d)  Any reference in this opinion to shares being  "non-assessable"  shall
          mean, in relation to  fully-paid  shares of the Company and subject to
          any contrary provision in any agreement in writing between the Company
          and the holder of shares,  that:  no  shareholder  shall be obliged to
          contribute  further  amounts to the capital of the Company,  either in
          order to  complete  payment  for their  shares,  to satisfy  claims of
          creditors of the Company,  or otherwise;  and no shareholder  shall be
          bound by an alteration of the Memorandum of Association or Bye-Laws of
          the Company after the date on which he became a shareholder, if and so
          far  as  the  alteration  requires  him  to  take,  or  subscribe  for
          additional shares, or in any way increases his liability to contribute
          to the share capital of, or otherwise to pay money to, the Company.

     Disclosure

     This  opinion  is  addressed  to you and may be relied  upon by Seward  and
     Kissel LLP to assist with their  delivery of an opinion in connection  with
     the issuance of the Securities and, save as referred to herein,  is neither
     to be transmitted to any other person,  nor 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  without  our
     prior written consent, except as may be required by law.

     We hereby  consent  to the  filing of this  opinion  as an  exhibit  to the
     Registration  Statement and to the references to our name in the prospectus
     contained  therein,  without  admitting  that we are  "experts"  within the
     meaning of the Securities Act, as amended,  or the rules and regulations of
     the  Commission  thereunder  with  respect to any part of 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.

     Further,  this opinion speaks as of its date and is strictly limited to the
     matters  stated herein and we assume no obligation to review or update this
     opinion if applicable  laws or the existing facts or  circumstances  should
     change.

     This  opinion is  governed by and is to be  construed  in  accordance  with
     Bermuda  law.  It is given on the  basis  that it will not give rise to any
     legal  proceedings  with  respect  to it in  any  jurisdiction  other  than
     Bermuda.  Further,  this  opinion  speaks  as of its date  and is  strictly
     limited to the matters  stated in it and we assume no  obligation to review
     or  update  this  opinion  if  applicable  law or  the  existing  facts  or
     circumstances should change.


Yours faithfully

/s/ Appleby Spurling Hunter


<PAGE>


                                    SCHEDULE

1.   Certified  copies  of  the  following   documents  of  the  Certificate  of
     Incorporation,  Memorandum  of  Association  and the Amended  and  Restated
     Bye-laws (the "Bye-laws") of the Company.

2.   An electronic copy of the Registration  Statement on Form S-3, dated August
     11, 2004, under the United States Securities Act of 1933, as amended.









d500664_ex5.1

</TEXT>
</DOCUMENT>
