Exhibit 9(y)


[Janus letterhead]


December 8, 2004

Janus Investment Fund
151 Detroit Street
Denver, CO  80206-4805

Re:      Public Offering of Janus Explorer Fund and Janus Research Fund

Gentlemen:

I have acted as counsel for Janus Investment Fund, a Massachusetts business
trust (the "Trust"), in connection with the filing with the Securities and
Exchange Commission of a post-effective amendment to the Trust's registration
statement with respect to the proposed sale of shares of beneficial interest,
$0.01 par value, of Janus Explorer Fund and Janus Research Fund (the "Shares").

I have examined the Trust's Agreement and Declaration of Trust and Bylaws, as
amended, the proceedings of its trustees relating to the authorization, issuance
and proposed sale of the Shares, and such other records and documents as I have
deemed relevant. Based upon such examination, it is my opinion that upon the
issuance and sale of the Shares in the manner contemplated by the aforesaid
post-effective amendment to the Trust's registration statement, such Shares will
be legally issued, fully paid and nonassessable.

I hereby consent to the filing of this opinion as an exhibit to the
above-referenced registration statement. This opinion is for the exclusive use
of the Trust in connection with the filing of such post-effective amendment to
the Trust's registration statement with the Securities and Exchange Commission
(and certain state securities commissions) and is not to be used, circulated,
quoted, relied upon or otherwise referred to by any other person or for any
other purpose. This opinion is given as of the date hereof and I render no
opinion and disclaim any obligation to revise or supplement this opinion based
upon any change in applicable law or any factual matter that occurs or comes to
my attention after the date hereof.

Very truly yours,

/s/Kelley Abbott Howes

Kelley Abbott Howes