Exhibit 8.2

                              [Letterhead of Torys]


                                                   May 18, 2001
McNaughton Apparel Group Inc.
463 Seventh Avenue
New York, New York 10018

     Re: Federal Income Tax Consequences of Agreement and Plan of Merger

Gentlemen and Ladies:

     We have acted as counsel for McNaughton Apparel Group Inc., a Delaware
corporation (the "Company"), in connection with the proposed merger (the
"Merger") of the Company with and into MCN Acquisition Corp., a Delaware
corporation ("Merger Sub") and a direct wholly owned subsidiary of Jones
Apparel Group, Inc., a Pennsylvania corporation ("Parent"), pursuant to an
Agreement and Plan of Merger dated as of April 13, 2001, among Parent, Merger
Sub and the Company (the "Merger Agreement").  In the Merger each issued and
outstanding share of common stock, par value $.01 per share, of the Company
("Company Common Stock"), other than Appraisal Shares (as such term is
defined in the Merger Agreement) and shares of Company Common Stock held by
the Company (as treasury stock), Parent or Merger Sub immediately prior to
the effective time of the Merger, will be converted into a right to receive a
unit consisting of a fraction of a fully paid and non-assessable share of
common stock, par value $.01 per share, of Parent and an amount of cash.

      In that connection you have requested our opinion regarding certain
federal income tax consequences of the Merger.  In reaching the opinion
expressed below, we have examined the Merger Agreement, the Form S-4 filed
pursuant to the Securities Act of 1933 in connection with the Merger (the
"Registration Statement"), the representations made to us by the Company and
Parent in their respective letters to us, each dated the date hereof, which
have been delivered to us for purposes of this opinion (the "Representation
Letters"), and such other documents and corporate records as we have deemed
necessary or appropriate for purposes of this opinion.  In addition, we have
assumed that:

          (i)   original documents submitted to us (including signatures
                thereto) are authentic, documents submitted as copies conform
                to the original documents, and that all such documents have
                been (or will be by the Merger) duly and validly executed and
                delivered where due execution and delivery are a prerequisite
                to the effectiveness thereof;



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          (ii)  the Merger will be consummated in accordance with the
                current terms of the Merger Agreement, without waiver,
                modification or breach of any of the material terms and
                conditions thereof;

          (iii) the statements concerning the Merger set forth in the
                Registration Statement and the other documents referred to
                herein are and, as of all relevant times, will be true,
                accurate and complete;

          (iv)  the representations set forth in each of the Representation
                Letters are and, as of all relevant times, will be true,
                accurate and complete; and

          (v)   no actions have been (or will be) taken which are
                inconsistent with any representation contained in either of
                the Representation Letters.

     If any of the above mentioned assumptions are untrue for any reason or
if the Merger is consummated in a manner inconsistent with the manner
described in the Merger Agreement or the Registration Statement, the opinion
expressed below may not be relied upon.

     Based upon and subject to the foregoing, it is our opinion that (i) the
Merger will constitute a "reorganization" within the meaning of
Section 368(a) of the Internal Revenue Code of 1986, as amended (the "Code"),
and (ii) each of Parent, Merger Sub and the Company will be a party to the
reorganization within the meaning of Section 368(b) of the Code.

     This opinion is intended solely for your use and may not be relied upon
by any other person without our express written permission.  Notwithstanding
the foregoing, we consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name under the headings "Legal
Matters" and  "THE MERGER - Material United States Federal Income Tax
Consequences of the Merger" in the Registration Statement.

                                       Very truly yours,

                                       /s/ Torys