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                                                                     EXHIBIT 8.3

                                DAVID KING & CO.
                                ATTORNEYS-AT-LAW


FIRST FLOOR                                                 TEL: (246) 427-3174
TRIDENT HOUSE                                               TEL: (246) 426-9246
LOWER BROAD STREET                                          TEL: (246) 436-5973
BRIDGETOWN, BARBADOS      e-mail: daveking@sunbeach.net     FAX: (246) 436-9541
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                                                                  April 17, 2002


Nabors Industries Ltd.
c/o The Corporate Secretary Limited
Whitepark House
White Park Road
Bridgetown, Barbados

Gentlemen:

         We have acted as special counsel to Nabors Industries Ltd., a Bermuda
exempted company ("Nabors Bermuda"), in connection with (i) the Merger, as
defined and described in the Agreement and Plan of Merger, dated as of January
2, 2002 (the "Agreement"), among Nabors Bermuda, Nabors Industries, Inc., a
Delaware corporation ("Nabors Delaware"), Nabors US Holdings Inc., a Delaware
corporation and a wholly owned subsidiary of Nabors Bermuda ("US Holdings"), and
Nabors Acquisition Corp. VIII, a Delaware corporation and a wholly owned
subsidiary of US Holdings ("Merger Sub"), and (ii) the preparation and filing of
the registration statement on Form S-4 (the "Registration Statement") with the
Securities and Exchange Commission (the "SEC") under the Securities Act of 1933,
as amended, on January 2, 2002 and as amended on March 22, 2002 and on April 17,
2002, which includes the proxy statement/prospectus (the "Proxy
Statement/Prospectus"). This opinion is being furnished to you at your request.
We are qualified to practice law in Barbados only and accordingly no opinion is
expressed herein as to the laws of any jurisdiction other than Barbados.
Capitalized terms used but not otherwise defined herein shall have the meaning
ascribed thereto in the Agreement.

         In connection with this opinion, we have examined the Agreement, the
Registration Statement and such other documents and corporate records as we have
deemed necessary or appropriate in order to enable us to render the opinion
below. We have relied upon statements, representations, and covenants made by
Nabors Delaware, Nabors Bermuda, US Holdings, and Merger Sub. For purposes of
this opinion, we have assumed (i) the validity and accuracy of the documents and
corporate records that we have examined and the facts and representations
concerning the Merger that have come to our attention during our engagement,
(ii) the genuineness of all signatures, the legal capacity of all natural
persons, the authenticity of all documents submitted to us as originals, the
conformity to original documents of all documents submitted to us as certified
or photostatic copies and the authenticity of the originals of such documents,
and (iii) that the Merger will be consummated in accordance with the terms of
the Agreement and as described in the Registration Statement and that none of
the terms and conditions contained therein will have been waived or modified in
any respect prior to the effective date of the Merger. Our opinion is
conditioned upon, among other things, the initial and continuing truth,
accuracy, and completeness of the items described above on which we are relying.


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NABORS INDUSTRIES LTD.                                                    PAGE 2
c/o The Corporate Secretary Limited


         In rendering our opinion, we have considered the applicable provisions
of Barbados tax law, including existing statutory and regulatory provisions,
pertinent judicial authorities, and such other authorities as we have considered
relevant. It should be noted that statutes, regulations, and judicial decisions
are subject to change at any time (possibly with retroactive effect). A change
in the authorities or the truth, accuracy, or completeness of any of the facts,
information, documents, corporate records, covenants, statements,
representations, or assumptions on which our opinion is based could affect our
conclusions.

         Although the discussion in the Proxy Statement/Prospectus under the
caption "Income Tax Consequences of the Reorganization - Barbados Income Tax
Consequences of the Reorganization" (the "Discussion") does not purport to
discuss all possible Barbados income tax consequences of the Merger, we are of
the opinion that, based solely upon and subject to the limitations,
qualifications, exceptions, and assumptions set forth herein and in the
Discussion, such Discussion constitutes, in all material respects, a fair and
accurate summary under current law of the anticipated Barbados income tax
consequences of the Merger.

         This opinion addresses only the matters expressly set forth in this
letter, and no other opinion is to be implied or inferred. Further, there can be
no assurances that the opinion expressed herein will be accepted by the Barbados
Department of Inland Revenue or, if challenged, by a court. The opinion is
expressed as of the date hereof, and we are under no obligation to supplement or
revise our opinion to reflect any changes (including changes that have
retroactive effect) (i) in applicable law or (ii) in any fact, information,
document, corporate record, covenant, statement, representation, or assumption
stated herein that becomes untrue, incorrect, or incomplete.

         This letter is furnished to you for use in connection with the Merger,
as described in the Agreement and the Proxy Statement/Prospectus, and is not to
be used, circulated, quoted, or otherwise referred to for any other purpose
without our express written permission. We hereby consent to the filing of this
opinion as an exhibit to the Registration Statement and to the use of our name
under the caption "Legal Matters" in the Proxy Statement/Prospectus. In giving
such consent, we do not thereby admit that we are in the category of persons
whose consent is required under Section 7 of the Securities Act of 1933, as
amended, or the rules and regulations of the SEC thereunder.


                                            Sincerely,

                                            /s/ David King & Co.

                                            David King & Co.







