Exhibit 5.1

                                  June 15, 2004

TOR Minerals International, Inc.
722 Burleson
Corpus Christi, Texas 78102

         Re:      Registration Statement on Form S-3 (No. 333-114483)

Ladies and Gentlemen:

         We have acted as counsel to TOR Minerals International, Inc., a
Delaware corporation (the "Company"), in connection with the registration under
the Securities Act of 1933, as amended (the "Act"), of the sale by certain
stockholders of the Company of up to 3,376,316 presently outstanding shares of
the Company's common stock, par value $0.25 per share ("Common Stock"), pursuant
to the Company's Registration Statement on Form S-3 (the "Registration
Statement") filed with the Securities and Exchange Commission under the Act.

         This opinion is being furnished to you in accordance with the
requirements of Item 601(b)(5) of Regulation S-K under the Act.

         In rendering this opinion, we have examined and are familiar with
originals or copies, certified or otherwise identified to our satisfaction, of
(1) the Registration Statement (together with the prospectus), (2) the
Certificate of Incorporation of the Company, as amended, (3) the Bylaws of the
Company, as amended (4) resolutions, minutes and records of the corporate
proceedings of the Company with respect to the issuance of the shares of Common
Stock and (5) such other documents and instruments as this firm has deemed
necessary for the expression of these opinions. In making the foregoing
examinations, this firm has assumed the genuineness of all signatures and the
authenticity of all documents submitted to this firm as originals, and the
conformity to original documents of all documents submitted to this firm as
certified, conformed or photostatic copies. As to various questions of fact
material to this opinion letter, and as to the content and form of the
Certificate of Incorporation, the Bylaws, minutes, records, resolutions and
other documents or writings of the Company, this firm has relied, to the extent
it deems reasonably appropriate, upon representations or certificates of
officers or directors of the Company and upon documents, records and instruments
furnished to this firm by the Company, without independent check or verification
of their accuracy.

         Based upon our examination, consideration of, and reliance on the
documents and other matters described above, this firm is of the opinion that
the shares of Common Stock are validly issued, fully paid and non-assessable.


TOR Minerals International, Inc.
June 15, 2004
Page 2



         This firm hereby consents to the filing of this opinion letter as an
exhibit to the Registration Statement and to references to our firm included in
or made a part of the Registration Statement. In giving this consent, this firm
does not admit that it comes within the category of person whose consent is
required under Section 7 of the Securities Act or the Rules and Regulations of
the Securities and Exchange Commission thereunder.



                                 Very truly yours,


                                 /s/ Jenkens & Gilchrist
                                 -----------------------
                                 Jenkens & Gilchrist, a Professional Corporation