<PAGE>
                                                                     EXHIBIT 8.2

                    [Letterhead of Appleby Spurling & Kempe]


                                                              6th September 2002

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

Dear Sirs

NABORS INDUSTRIES LTD. (THE "COMPANY")

We have acted as legal counsel in Bermuda to the Company and this opinion is
addressed to you in connection with the filing by the Company with the
Securities and Exchange Commission under the Securities Act of 1933, as amended,
of a Registration Statement on Form S-3 on 6th September 2002 in relation to the
registration of up to 1,000,000 Common Shares of par value US$0.001 each (the
"Shares") in the share capital of the Company (the "Registration Statement").

For the purposes of this opinion we have examined and relied upon the documents
listed, and in some cases 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, and such other documents examined by us, as originals, and the
         conformity to authentic original Documents of all Documents submitted
         to us, and such other documents examined by us, as certified,
         conformed, notarised, faxed or photostatic copies;

(b)      that each of the Documents and other such documentation which was
         received by electronic means is complete, intact and in conformity with
         the transmission as sent;

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

(d)      the authority, capacity and power of each of the persons signing the
         Documents (other than the Company);

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




<PAGE>
Nabors Industries Ltd.                -2-                       6 September 2002



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 the
statements in the Registration Statement under the caption "Bermuda Income Tax
Considerations" in so far as they purport to describe the provisions of the laws
of Bermuda referred to therein, are accurate and correct in all material
respects.

Reservation

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.

Disclosure

This opinion is addressed to you solely for your benefit and is neither to be
transmitted to any other person, nor relied upon by any other person or for any
other purpose nor quoted or referred to in any public document nor filed with
any governmental agency or person, without our prior written consent. We consent
to the filing of this opinion as an exhibit to the Registration Statement.

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 law or the existing facts or circumstances should change.

Yours faithfully

/s/ APPLEBY SPURLING & KEMPE


<PAGE>


                                    SCHEDULE


1.       A copy of the Registration Statement on Form S-3, pursuant to which the
         Company will register up to 1,000,000 Common Shares of par value
         US$0.001 each in the share capital of the Company.

2.       Certified copies of the Certificate of Incorporation, Memorandum of
         Association and Bye-laws for the Company (collectively referred to as
         the "Constitutional Documents").

3.       Certified copy of the minutes of meetings of the Board of Directors of
         the Company held 17th July, 2002 (the "Resolutions").

4.       A certified copy of the "Foreign Exchange Letter", dated 11 December,
         2001 and a letter of permission dated 15 April, 2002, issued by the
         Bermuda Monetary Authority, Hamilton Bermuda in relation to the
         Company.

5.       A certified copy of the "Tax Assurance", dated 7 January, 2002 issued
         by the Registrar of Companies for the Minister of Finance in relation
         to the Company.

6.       A Certificate of Compliance, dated 3rd September, 2002 issued by the
         Ministry of Finance in respect of the Company.

7.       The entries and filings shown in respect of the Company on the file of
         the Company maintained in the Register of Companies at office of the
         Registrar of Companies in Hamilton, Bermuda, as revealed by a search on
         3rd September 2002 (the "Company Search").

8.       The entries and filings shown in respect of the Company in the Supreme
         Court Causes Book maintained at the Registry of the Supreme Court in
         Hamilton, Bermuda, as revealed by a search on 3rd September 2002 in
         respect of the Company (the "Litigation Search").



