EX-5.1

Exhibit 5.1

(LINKLATERS LOGO)


		One Silk Street London EC2Y 8HQ Telephone (44-20) 7456 2000 Facsimile (44-20) 7456 2222 Group 4 Fax (44-20) 7374 9318 DX Box Number 10 CDE Direct Line 020 7456 3236 Direct Fax 020 7456 2222 justine.fender@linklaters.com

The Directors InterContinental Hotels Group PLC 67 Alma Road Windsor Berkshire SL4 3HD


		27 June 2005

Our Ref Mark Stamp/Justine Fender

NEW INTERCONTINENTAL HOTELS GROUP PLC (THE “COMPANY”)

1 This opinion is delivered in connection with the Company’s registration statement on Form S-8 (the “Registration Statement”) dated today’s date and filed under the United States Securities Act of 1933 relating to ordinary shares of the Company (“Ordinary Shares”) in connection with the grant of options or awards (as applicable) under the Company’s Executive Share Option Plan, Performance Restricted Share Plan, Short Term Deferred Incentive Plan and US Employee Stock Purchase Plan.

2 This opinion is limited to English law as applied by the English courts and is given on the basis that it will be governed by and construed in accordance with English law.

3 For the purposes of this opinion, we have examined and relied on copies of such corporate records and other documents, and reviewed such matters of law as we have deemed necessary or appropriate for the purpose of this opinion.

4 Upon the basis of and subject to the foregoing, but subject to any matters not disclosed to us, it is our opinion that the Company is a public limited company incorporated under the laws of England and Wales under the Companies Act 1985 and that all the necessary corporate action on the part of the Company, except for the grant of options or awards (as applicable) and the allotment of the shares on the exercise of the options or awards (as applicable), has been taken to authorise the issue of such Ordinary Shares and that upon issuance and payment, such Ordinary Shares will have been duly authorised and validly issued and will be fully paid and no further contributions in respect thereof will be required to be made to the Company by the holders thereof, by reason solely of their being such holders.

5 This opinion is given to you solely for use in connection with the filing of the Registration Statement. This opinion is strictly limited to matters dealt with herein and does not extend to and is not to be read as extending by implication to any other matter.

A list of the names of the partners and their professional qualifications is open to inspection at the above office. The partners are solicitors, registered foreign lawyers or European lawyers. The firm is regulated by the Law Society.

Please refer to www.linklaters.com/regulation for important information on the regulatory position of the firm.

1		This opinion is delivered in connection with the Company’s registration statement on Form S-8 (the “Registration Statement”) dated today’s date and filed under the United States Securities Act of 1933 relating to ordinary shares of the Company (“Ordinary Shares”) in connection with the grant of options or awards (as applicable) under the Company’s Executive Share Option Plan, Performance Restricted Share Plan, Short Term Deferred Incentive Plan and US Employee Stock Purchase Plan.

2		This opinion is limited to English law as applied by the English courts and is given on the basis that it will be governed by and construed in accordance with English law.

3		For the purposes of this opinion, we have examined and relied on copies of such corporate records and other documents, and reviewed such matters of law as we have deemed necessary or appropriate for the purpose of this opinion.

4		Upon the basis of and subject to the foregoing, but subject to any matters not disclosed to us, it is our opinion that the Company is a public limited company incorporated under the laws of England and Wales under the Companies Act 1985 and that all the necessary corporate action on the part of the Company, except for the grant of options or awards (as applicable) and the allotment of the shares on the exercise of the options or awards (as applicable), has been taken to authorise the issue of such Ordinary Shares and that upon issuance and payment, such Ordinary Shares will have been duly authorised and validly issued and will be fully paid and no further contributions in respect thereof will be required to be made to the Company by the holders thereof, by reason solely of their being such holders.

5		This opinion is given to you solely for use in connection with the filing of the Registration Statement. This opinion is strictly limited to matters dealt with herein and does not extend to and is not to be read as extending by implication to any other matter.


Yours faithfully
/s/ Linklaters
Linklaters