November 1, 2001

John Hancock Declaration Trust (the "Trust")
 on behalf of John Hancock V.A. Strategic Income Fund
  and John Hancock V.A. Financial Industries Fund (the "Funds")
101 Huntington Avenue
Boston, MA 02199

Ladies and Gentlemen:

In connection with the filing of a registration statement under the Securities
Act of 1933, as amended (the "Act"), on Form N-14, with respect to the shares of
beneficial interest of John Hancock V.A. Strategic Income Fund and John Hancock
V.A. Financial Industries Fund (the "Funds"), each a series of John Hancock
Declaration Trust (the "Trust"), a Massachusetts business trust, it is the
opinion of the undersigned that these shares when issued, will be legally
issued, fully paid and non-assessable.

In connection with this opinion it should be noted that the Trust is an entity
of the type generally known as a "Massachusetts business trust." Under
Massachusetts law, shareholders of a Massachusetts business trust may be held
personally liable for the obligations of the trust. However, the Trust's
Declaration of Trust disclaims shareholder liability for obligations of the
Trust and indemnifies any shareholder of the Funds, with this indemnification to
be paid solely out of the assets of the Fund. Therefore, the shareholder's risk
is limited to circumstances in which the assets of the Funds are insufficient to
meet the obligations asserted against the Funds' assets.

The undersigned hereby consents to the filing of a copy of this opinion as an
exhibit to the Trust's registration statement on Form N-14 and with the
Securities and Exchange Commission.

Sincerely,


/s/Brian E. Langenfeld
----------------------
Brian E. Langenfeld
Attorney and Assistant Secretary
John Hancock Advisers, Inc.