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EXHIBIT 5.1
Harry B. Sands & Co.
P.O. Box N-624
Nassau, Bahamas
22 June 2000
Steiner Leisure Limited
Suite 104A,
Saffrey Square,
Nassau, The Bahamas
Dear Sirs,
RE: FORM S-3 REGISTRATION STATEMENT
We have acted as Bahamian counsel to Steiner Leisure Limited, a company
incorporated under the laws of the Commonwealth of The Bahamas (the "Company"),
in connection with a Registration Statement on Form S-3 (no. 33-39174) (the
"Registration Statement") filed with the Securities and Exchange Commission
under the Securities Act of 1933 as amended (the "Act"), for the registration of
35,744 common shares of $.01 par value, of the Company (the "Selling Shareholder
Shares") being sold by the selling shareholders identified in the Registration
Statement (the "Selling Shareholders").
In that connection, we have examined originals, or copies certified or
otherwise identified to our satisfaction, of such documents, corporate records
and other instruments as we have deemed necessary for the purpose of this
opinion, including the current Memorandum and Articles of Association of the
Company.
Based on the forgoing, we are of the opinion, as follows:
1. The Company is a validly existing corporation under the laws
of Commonwealth of The Bahamas; and
2. The Selling Shareholder Shares have been validly issued to the
Selling Shareholders as fully paid and non-assessable.
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OPINION
22 JUNE 2000
Page 2
This opinion is limited to the laws of the Commonwealth of The Bahamas
at the date of this opinion, and no opinion is expressed to the laws of any
other jurisdiction other than that of the Commonwealth of The Bahamas.
We hereby consent to the filing of this opinion as part of the
Registration Statement and to the use of our name therein and in the Prospectus
under the captions "Risk Factors--We are not a United States Company and, as a
Result, There are Special Risks" and "Legal Matters."
Yours faithfully,
HARRY B. SANDS & COMPANY
/s/ BRYAN A. GLINTON
----------------------------
Bryan A. Glinton
