Exhibit 5.1

                               OPINION OF COUNSEL

                                 Rebecca Wilson
                                 Attorney at Law
                           2961W. MacArthur, Suite 120
                               Santa Ana, CA 92704
                      (714) 850-3356 / (714) 850-3368 (fax)

January 25, 2002


ZAP
117 Morris Street
Sebastopol, CA 95472

         Re:      Registration Statement on Form S-8

Gentleman:

I have  acted  as  counsel  for ZAP  (the  "Company"),  in  connection  with the
preparation and filing of the Company's Registration statement on Form S-8 under
the Securities Act of 1933, as amended, (the "Registration Statement"), relating
to 2,685,000  shares of the Company's  common stock, no par value,  (the "common
stock"),  issuable  pursuant  to  the  Company's  Consultants  Agreements,  (the
"Agreements") and Stock Compensation Plan, (the "Plan").

         I have examined the Certificate of Incorporation,  as amended,  and the
By-Laws of the Company and all amendments  thereto,  the Registration  Statement
and  originals,  or copies  certified  to my  satisfaction,  of such records and
meetings,  written  actions  in lieu of  meetings,  or  resolutions  adopted  at
meetings,  of the  directors  of the  Company,  and  such  other  documents  and
instruments  as in my judgment  are  necessary  or  appropriate  to enable me to
render the opinions expressed below.

         Based on the foregoing examination, I am of the opinion that the shares
of common Stock  issuable with the  Agreement  and the Plan are duly  authorized
and, when issued in accordance  with the Agreement and the Plan, will be validly
issued, fully paid and non-assessable.

         Further,  I consent to the filing of this  opinion as an exhibit to the
Registration Statement.

Very truly yours,

/s/ Rebecca Wilson
------------------------
    Rebecca Wilson, Esq.