EXHIBIT 5
                                    ---------









               Appleby Spurling Hunter

               Barristers & Attorneys

               22 Victoria Street
               Hamilton HM 12, Bermuda
               Telephone: 441 295 2244
               Fax: 441 292 8666/441 295 5328

                                                                December 9, 2005


          Securities and Exchange Commission
          100 F Street, N.E.
          Washington, D.C. 20549

          Ladies and Gentlemen:

          Sea Containers Ltd.
          -------------------

          We have acted as Bermuda  counsel for Sea  Containers  Ltd., a Bermuda
          company (the "Company"), in connection with its 2004 Stock Option Plan
          and subsidiary  2004 United  Kingdom Stock Option Plan  (collectively,
          the  "Plan").  The Plan  provides  for the sale upon the  exercise  of
          option  of up to  500,000  shares  (the  "Additional  Shares")  of the
          Company's  class A common  shares,  par value $0.01 each,  and class B
          common  shares,  par value  $0.01  each,  and up to and an  additional
          500,000 preferred share purchase rights (the "Additional Rights"). The
          Additional  Shares  may  be  authorised  but  unissued  shares.   Each
          Additional Right will be issued in connection with the issuance of one
          of the  Additional  Shares  and  prior  to the  Distribution  Date (as
          defined in the rights  agreement  providing  for the  preferred  share
          purchase rights), will be transferable with and only with, and will be
          evidenced by the certificate evidencing, such Additional Share.

          We have  examined  the  originals,  or copies  certified  or otherwise
          identified to our  satisfaction,  of such  corporate  records and such
          other  documents as we have deemed relevant as a basis for our opinion
          hereinafter expressed.

          Based  on the  foregoing,  we are of the  opinion  that up to  500,000
          previously unissued Additional Shares and Additional Rights, when they
          are paid for in accordance  with the terms of the Plan and the options
          granted  thereunder,  and when  certificates for the Additional Shares
          and  Additional  Rights are duly executed under the common seal of the
          Company,  will be legally  issued,  and the Additional  Shares will be
          fully-paid and non-assessable.

          The   foregoing    reference   to   the   Additional    Shares   being
          "non-assessable"  shall mean, in relation to fully-paid  shares of the
          Company,  and subject to any contrary  provision  in any  agreement in
          writing between the Company and the holder of






          Additional Shares,  that no shareholder shall be obliged to contribute
          further  amounts  to the  capital of the  Company,  either in order to
          complete  payment for their  Additional  Shares,  to satisfy claims of
          creditors of the Company,  or otherwise;  and no shareholder  shall be
          bound by an alteration of the Memorandum of Association or Bye-Laws of
          the Company,  after the date on which he became a shareholder,  if and
          so far as the  alteration  requires  him to  take,  or  subscribe  for
          additional  shares  of  the  Company,  or in  any  way  increases  his
          liability to  contribute  to the share capital of, or otherwise to pay
          money to the Company.

          In  rendering  this  opinion,  we do not express any opinion as to the
          laws of any jurisdiction other than the laws of Bermuda.

          We hereby  consent to the filing of this  opinion as an exhibit to the
          Company's Form S-8  Registration  Statement for the Additional  Shares
          and Additional Rights.

          Yours faithfully

          APPLEBY SPURLING HUNTER

          /s/Appleby Spurling Hunter