EXHIBIT 5.1


April 26, 2004






Royal Caribbean Cruises Ltd.
1050 Caribbean Way
Miami, Florida 33132



Ladies and Gentlemen:

We have acted as special counsel as to matters of Liberian and maritime law to
Royal Caribbean Cruises Ltd., a Liberian corporation (the "COMPANY"), and in
such capacity we have assisted in the preparation and filing with the Securities
and Exchange Commission under the Securities Act of 1933, as amended (the
"SECURITIES ACT"), of a Registration Statement on Form F-3 (such registration
statement and any additional registration statement filed pursuant to Rule
462(b) is referred to as the "REGISTRATION STATEMENT") in respect of the
contemplated issuance by the Company from time to time of up to $1,000,000,000
aggregate public offering price (or any such further aggregate public offering
price as may be registered pursuant to Rule 462(b)) or the equivalent thereof in
one or more foreign currencies, currency units or composite currencies of (i)
senior debt securities (the "DEBT SECURITIES"), which may be issued pursuant to
an Indenture dated as of July 15, 1994, as amended (the "INDENTURE"), between
the Company and The Bank of New York (as successor to NationsBank of Georgia,
National Association); (ii) shares of preferred stock of the Company, par value
$.01 per share (the "PREFERRED STOCK"); and (iii) shares of common stock of the
Company, par value $.01 per share (the "COMMON STOCK"). The Debt Securities,
Preferred Stock and Common Stock are hereafter referred to as the "SECURITIES."

As such counsel, we have examined (i) the forms of underwriting agreements for
debt and equity securities among the Company and representatives of the
underwriters to be named in a terms agreement (the "UNDERWRITING AGREEMENTS"),
(ii) the Indenture and (iii) such other papers, documents and certificates of
public officials and certificates of officers of the Company as we have deemed
relevant and necessary as the basis for the opinions hereafter expressed.

In such examinations, we have assumed the genuineness of all signatures and the
authenticity of all documents submitted to us as originals and the conformity to
original documents of all documents submitted to us as conformed or photostatic
copies.





Royal Caribbean Cruises Ltd.
April 26, 2004
                                                                          Page 2


This opinion is limited to the laws of the Republic of Liberia. In rendering
this opinion, we have relied on opinions of counsel in Liberia rendered in
transactions which we consider to be sufficiently similar to those contemplated
hereby in order to afford a satisfactory basis for such opinion, and upon our
independent examinations of the Liberian Corporation Law of 1948 (Chapter 1 of
Title 4 of the Liberian Code of Laws of 1956, effective March 1, 1958 as amended
to July, 1973), the Liberian Business Corporation Act of 1976 (Title 5 of the
Liberian Code of Laws Revised, effective January 3, 1977, as amended), and the
Liberian Revenue and Finance Law (Title 37 of the Liberian Code Laws Revised,
effective July 1, 1977), in each case as contained in pamphlets delivered to us
by Liberian Corporation Services, Inc. and The Liberian International Ship and
Corporate Registry, LLC (who have advised us to the best of their knowledge such
laws remain in effect on the date hereof) and our knowledge and interpretation
of analogous laws of the United States.

Based upon the foregoing and having regard to legal considerations which we deem
relevant, we are of the opinion that:

1.    Upon the fixing of the designations, relative rights, preferences and
      limitations of any series of Preferred Stock by the Board of Directors of
      the Company and proper and valid filing with the Minister of Foreign
      Affairs of Liberia of a statement setting forth a copy of the resolution
      of the Board of Directors establishing such series of Preferred Stock and
      the number of shares of such Preferred Stock to be issued, all in
      conformity with the Company's Restated Articles of Incorporation and upon
      the approval by the Board of Directors of the Company of the specific
      terms of the issuance, all necessary corporate action on the part of the
      Company will have been taken to authorize the issuance and sale of such
      series of Preferred Stock proposed to be sold by the Company, and when
      such shares of Preferred Stock are issued and delivered against payment
      therefor in accordance with the applicable Underwriting Agreement or other
      agreement or upon conversion or exchange in accordance with the terms of
      any other Security that has been duly authorized, issued, paid for and
      delivered, such shares will be validly issued, fully paid and
      non-assessable.

2.    The shares of Common Stock, when the terms of the issuance and sale
      thereof have been duly approved by the Board of Directors of the Company
      in conformity with the Company's Restated Articles of Incorporation and
      when issued and delivered against payment therefor in accordance with the
      applicable Underwriting Agreement or other agreement or upon conversion or
      exchange of any Security that has been duly authorized, issued, paid for
      and delivered, will be validly issued, fully paid and non-assessable.

3.    When the specific terms of a particular Debt Security have been duly
      authorized by the Board of Directors of the Company and established in
      accordance with the Indenture and such Debt Security has been duly
      executed, authenticated, issued for value and delivered in accordance with
      the Indenture, such Debt Security will be a binding obligation of the
      Company, enforceable against the Company in accordance with its terms,
      except as enforceability may be limited by bankruptcy, insolvency,
      reorganization, fraudulent conveyance or other laws relating to or
      affecting creditors' rights generally and subject to general principles of
      equity, including application by a court of competent jurisdiction of
      principles of good faith, fair dealing, commercial reasonableness,
      materiality, unconscionability and conflict with public policy or other
      similar principles.

Royal Caribbean Cruises Ltd.
April 26, 2004
                                                                          Page 3



We hereby consent to the use of this opinion as an exhibit to the Registration
Statement and to the reference to our name in the prospectus contained therein.
In giving such consent, we do not thereby admit that we are in the category of
persons whose consent is required under Section 7 of the Securities Act.

This opinion may not, without our prior written consent, be used or relied upon
by any person other than (i) the Company and (ii) solely with respect to the
opinions expressed herein under the laws of Liberia, Fried, Frank, Harris,
Shriver & Jacobson and Davis Polk & Wardwell.

Very truly yours,

WATSON, FARLEY & WILLIAMS
/s/ WATSON, FARLEY & WILLIAMS