EXHIBIT 5
 
                     [WILLKIE FARR & GALLAGHER LETTERHEAD]
 
February 14, 1997
 
Fine Host Corporation
3 Greenwich Office Park
Greenwich, Connecticut 06831
 
Re: Public Offering of Common Stock
   of Fine Host Corporation
 
Ladies and Gentlemen:
 
    We have acted as counsel to Fine Host Corporation (the "Company"), a
corporation organized under the laws of the State of Delaware, in connection
with the preparation of a Registration Statement on Form S-1 (the "Registration
Statement") relating to the offer and sale by certain selling stockholders (the
"Offering") of up to 223,000 shares of the Common Stock of the Company, par
value $.01 per share (the "Shares").
 
    We have examined copies of the Restated Certificate of Incorporation and
By-Laws of the Company, the Registration Statement, all resolutions adopted by
the Company's Board of Directors and other records and documents that we have
deemed necessary for the purpose of this opinion. We have also examined such
other documents, papers, statutes and authorities as we have deemed necessary to
form a basis for the opinion hereinafter expressed.
 
    In our examination, we have assumed the genuineness of all signatures and
the conformity to original documents of all copies submitted to us. As to
various questions of fact material to our opinion, we have relied on statements
and certificates of officers and representatives of the Company and public
officials.
 
    Based on the foregoing, we are of the opinion that (i) the Company has been
duly organized and is validly existing as a corporation in good standing under
the laws of the State of Delaware and (ii) the Shares, when duly sold, issued
and paid for in accordance with the terms of the Prospectus included as part of
the Registration Statement, will be duly authorized and validly issued and will
be fully paid and non-assessable.
 
    We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement, and to the reference to us in the Prospectus included as
part of the Registration Statement.
 
Very truly yours,
 
/s/ WILLKIE FARR & GALLAGHER
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