Exhibit 14.1

             CODE OF ETHICS FOR OFFICERS, DIRECTORS AND EMPLOYEES OF
                              ARK RESTAURANTS CORP.

1. TREAT IN AN ETHICAL MANNER THOSE TO WHOM ARK RESTAURANTS CORP. HAS AN
OBLIGATION

The officers, directors and employees of Ark Restaurants Corp. (the "Company")
are committed to performing the business of the Company with the highest levels
of honesty and ethical conduct.

For the communities in which we live and work we are committed to acting as
concerned and responsible neighbors, reflecting all aspects of good citizenship.
For our shareholders we are committed to pursuing sound growth and earnings
objectives and to exercising prudence in the use of our assets and resources.
For our suppliers and partners we are committed to fair competition and the
sense of responsibility required of a good customer and teammate.

2. OBEY THE LAW

We will conduct our business in accordance with all applicable laws and
regulations. Compliance with the law does not comprise our entire ethical
responsibility. Rather, it is a minimum, absolutely essential condition for
performance of our duties. In conducting business, we shall:

     A.   STRICTLY ADHERE TO ALL ANTITRUST LAWS

     Officer, directors and employees must strictly adhere to all antitrust
     laws. These laws prohibit practices in restraint of trade such as price
     fixing and boycotting suppliers or customers. They also bar pricing
     intended to run a competitor out of business; disparaging, misrepresenting,
     or harassing a competitor; stealing trade secrets; bribery; and kickbacks.

     B.   STRICTLY COMPLY WITH ALL SECURITIES LAWS

     In our role as a publicly owned company, we must always be alert to and
     comply with the security laws and regulations of the United States.

          I.   DO NOT ENGAGE IN SPECULATIVE OR INSIDER TRADING

          Federal law and Company policy prohibits officers, directors and
          employees, directly or indirectly through their families or others,
          from purchasing or selling Company stock while in the possession of
          material, non-public information concerning the Company. This same
          prohibition applies to trading in the stock of other publicly held
          companies on the basis of material, non-public information.

          Material, non-public information is any information that could
          reasonably be expected to affect the price of a stock. If an officer,
          director or employee is considering buying or selling a stock because
          of inside information they possess, they should assume that such
          information is material. It is also important for the officer,
          director or employee to keep in mind that if any trade they make
          becomes the subject of an investigation by the government, the trade
          will be viewed after-the-fact with the benefit of hindsight.







          Consequently, officers, directors and employees should always
          carefully consider how their trades would look from this perspective.

          Two simple rules can help protect you in this area: (1) Do not use
          non-public information for personal gain. (2) Do not pass along such
          information to someone else who has no need to know.

          II.  BE TIMELY AND ACCURATE IN ALL PUBLIC REPORTS

          As a public company, the Company must file disclosure reports with the
          United States Securities and Exchange Commission that are full, fair,
          accurate, timely and understandable. Officers, directors and
          management of the Company are responsible for ensuring that these
          reports and the other public communications made by the Company are
          accurate and fairly present the financial condition and operating
          results of the Company.

          Securities laws are vigorously enforced. Violations may result in
          severe penalties including forced sales of parts of the business and
          significant fines against the Company. There may also be sanctions
          against individual employees including substantial fines and prison
          sentences.

          The principal executive officer and principal financial officer of the
          Company will certify to the accuracy of reports filed with the SEC in
          accordance with the Sarbanes-Oxley Act of 2002. Officers and directors
          who knowingly or willingly make false certifications may be subject to
          criminal penalties or sanctions including fines and imprisonment.

3. AVOID CONFLICTS OF INTEREST

Our officers, directors and employees have an obligation to give their complete
loyalty to the best interests of the Company. They should avoid any action that
may involve, or may appear to involve, a conflict of interest with the Company.
Officers, directors and employees should not have any financial or other
business relationships with suppliers, customers or competitors that might
impair the independence of any judgment they may need to make on behalf of the
Company.

Officers, directors and employees are under a continuing obligation to disclose
any situation that presents the possibility of a conflict or disparity of
interest between the officer, director or employee and the Company. Disclosure
of any potential conflict is the key to remaining in full compliance with this
policy.

4. AVOID ILLEGAL AND QUESTIONABLE GIFTS OR FAVORS

The sale and marketing of our products and services should always be free from
even the perception that favorable treatment was sought, received, or given in
exchange for the furnishing or receipt of business courtesies. Officers,
directors and employees of the Company will neither give nor accept business
courtesies that constitute, or could be reasonably perceived as constituting,
unfair business inducements or that would violate law, regulation or policies of
the Company, or could cause embarrassment to or reflect negatively on the
Company's reputation.

5. KEEP ACCURATE AND COMPLETE RECORDS









We must maintain accurate and complete Company records. Transactions between the
Company and outside individuals and organizations must be promptly and
accurately entered in our books in accordance with generally accepted accounting
practices and principles. No one should rationalize or even consider
misrepresenting facts or falsifying records. It will not be tolerated and will
result in disciplinary action.

6. ENFORCEMENT

The Company has empowered its Audit Committee to enforce this Code of Ethics and
Business Conduct. The Audit Committee will report to the Board of Directors at
least once each year regarding the general effectiveness of this Code, the
Company's controls and reporting procedures and the Company's business conduct.
Officers, directors and employees of the Company who do not adhere to this Code
will be held accountable for their actions.

7. DISCIPLINARY MEASURES

The Company shall consistently enforce its Code of Ethics and Business Conduct
through appropriate means of discipline. Violations of the Code shall be
promptly reported to the Audit Committee. The Audit Committee shall determine
whether violations of the Code have occurred and, if so, shall determine the
disciplinary measures to be taken against any employee or agent of the Company
who has so violated the Code.

The disciplinary measures, which may be invoked at the discretion of the Audit
Committee, include, but are not limited to, counseling, oral or written
reprimands, warnings, probation or suspension without pay, demotions, reductions
in salary, termination of employment and restitution.

Persons subject to disciplinary measures shall include, in addition to the
violator, others involved in the wrongdoing such as (i) persons who fail to use
reasonable care to detect a violation, (ii) persons who if requested to divulge
information withhold material information regarding a violation, and (iii)
supervisors who approve or condone the violations or attempt to retaliate
against employees or agents for reporting violations or violators.