Exhibit 8.1

              Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

                              One Financial Center
                           Boston, Massachusetts 02111

                                                                617 542 6000
                                                                617 542 2241 fax


                                          November 5, 2002


John Hancock Life Insurance Company
John Hancock Place
200 Clarendon Street
Boston, Massachusetts  02116

         Re:  John Hancock Life Insurance Company SignatureNotes/sm/

Ladies and Gentlemen:

         At your request, we have examined the Registration Statement on Form
S-3 (the "Registration Statement"), filed on April 3, 2002, as amended and
supplemented through the date hereof, with the Securities and Exchange
Commission in connection with the registration under the Securities Act of 1933,
as amended, of $3,000,000,000 aggregate principal amount of debt obligations of
John Hancock Life Insurance Company, a Massachusetts corporation (the
"Company"). The Registration Statement is for the proposed issue and sale of
SignatureNotes/sm/ which are due twelve months or more from the date of their
issue (the "Notes").

         We have examined instruments, documents, and records that we deemed
relevant and necessary for the basis of our opinion hereinafter expressed. Based
on such examination, and subject to the following paragraph, the discussion in
the Registration Statement under the heading "United States Federal Taxation"
and in the Pricing Supplement dated November 5, 2002 under the heading "United
States Federal Income Taxation", subject to the limitations and qualifications
described therein, constitutes our opinion as to the material United States
federal income tax consequences of ownership and disposition of the Notes.

         Our opinion is limited to the tax matters specifically covered under
the heading "United States Federal Taxation" in the Registration Statement and
under the heading "United States Federal Income Taxation" in the Pricing
Supplement dated November 5, 2002, and we have not been asked to address, nor
have we addressed, any other tax matters. In addition, as indicated in the
Registration Statement, the discussion sets forth our opinion as to the material
United States federal income tax consequences of the ownership and disposition
of the Notes as applied to original holders purchasing the Notes at the issue
price and holding the Notes as capital assets as defined in Section 1221 of the
Internal Revenue Code of 1986. Holders are advised to consult their own tax
advisors with regard to the application of the income tax laws to their
particular situations as well as any tax consequences arising under the laws of
any state, local or foreign tax jurisdiction.

                  Boston New York Reston Washington New Haven



MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.

John Hancock Life Insurance Company
November 5, 2002
Page 2


         We hereby consent to the reference to our name and our opinion under
the headings "United States Federal Taxation" and "Legal Opinions" in the
Registration Statement and the filing of this opinion as an exhibit to the
Registration Statement.


                                          Very truly yours,

                                          /s/  Mintz, Levin, Cohn, Ferris,
                                               Glovsky and Popeo, P.C.

                                          Mintz, Levin, Cohn, Ferris,
                                          Glovsky and Popeo, P.C.





                  Boston New York Reston Washington New Haven