1 EXHIBIT 5.1 [MORRISON & FOERSTER LLP LETTERHEAD] October 28, 1996 Nellcor Puritan Bennett Incorporated 4280 Hacienda Drive Pleasanton, California 94588 Gentlemen: At your request, we have examined the Registration Statement on Form S-4 dated October 28, 1996, filed with the Securities and Exchange Commission (the "SEC") on that date in connection with the registration under the Securities Act of 1933, as amended, of 3,830,151 shares of your Common Stock, $.001 par value ("Common Stock") issuable in connection with the merger (the "Merger") contemplated by that certain Amended and Restated Agreement and Plan of Merger, dated as of September 9, 1996 (as amended, the "Merger Agreement"), by and among Nellcor Puritan Bennett Incorporated, a Delaware corporation, and Aequitron Medical, Inc. ("Aequitron"), a Minnesota corporation. As your counsel in connection with the Registration Statement, we have examined (i) the proceedings taken by you in connection with entering into the Merger Agreement, (ii) the proceedings taken by you in connection with the authorization of the issuance of the shares of your Common Stock to be issued in the Merger (the "Shares"), and (iii) originals or copies, certified or otherwise identified to our satisfaction, of such corporate records, certificates of public officials and other documents as we have deemed necessary to render this opinion. Based upon the foregoing, it is our opinion that the Shares, when issued in the Merger following approval of shareholders of Aequitron of the Merger and consummation thereof in accordance with the Merger Agreement, will be validly issued, fully paid and nonassessable shares of Common Stock. We express no opinion as to the matters governed by any laws other than the State of Delaware which are in effect as of the date hereof. We consent to the use of this opinion as an exhibit to the Registration Statement and to the reference to us under the caption "Legal Matters" in the Proxy Statement/Prospectus forming a part of the Registration Statement. Very truly yours, Morrison & Foerster LLP