EXHIBIT 5.2










                                                               November 16, 1999




Visible Genetics Inc.
Suite 1000, Box 333
700 Bay Street
Toronto, Ontario
Canada M5G 1Z6

Gentlemen:

         RE:      Visible Genetics Inc.
                  REGISTRATION STATEMENT ON FORM F-3

         We have acted as Canadian counsel to Visible Genetics Inc. (the
"Company") in connection with the preparation and filing with the Securities and
Exchange Commission of the Company's Registration Statement on Form F-3 (the
"Registration Statement") under the Securities Act of 1933, as amended (the
"Securities Act") relating to the registration of (the "Offering") 5,283,758
common shares (the "Common Shares"), to be sold by the Selling Shareholders.
Capitalized terms used herein but not otherwise defined shall have the
respective meanings set forth in the Registration Statement.

         In connection with the foregoing, we have examined copies of the
Company's Amended and Restated Articles of Incorporation (the "Restated Articles
of Incorporation") and the Amended and Restated by-laws, the Registration
Statement and all exhibits thereto, the minutes of various meetings or unanimous
written consents of the Board of Directors of the Company, and originals,
photocopies or certified copies of all such records of the Company, and all such
agreements, certificates of public officials, certificates of officers and
representatives of the Company and others, and such other documents, papers,
statutes and authorities, as we deemed necessary to form the basis of the
opinion hereinafter expressed. In such examination, we have assumed the
genuineness of all signatures, the authenticity and accuracy of all documents
submitted to us as originals and the conformity to original documents of all
documents supplied to us as copies. As to various questions of fact material to
such opinion, we have relied upon statements and certificates of officers of the
Company and others.

         Based upon the foregoing and subject to the qualifications and
limitations stated herein, we are of the opinion that the Common Shares, when
sold by the Selling Shareholders, will be validly issued, fully paid and
non-assessable.




         We hereby consent to the use of this opinion as an exhibit to the
Registration Statement and to the use of our name under the captions "Service
and Enforcement of Legal Process" and "Legal Matters" in the Prospectus forming
a part of the Registration Statement. We hereby also consent to the
incorporation by reference of this consent into a subsequent registration
statement filed by the Company pursuant to Rule 462(b) under the Securities Act
relating to the offering covered by the Registration Statement. In giving such
consent, we do not thereby concede that we are in the category of persons whose
consent is required under Section 7 of the Securities Act or the rules and
regulations promulgated thereunder, or that we are "experts" within the meaning
of the Securities Act or the rules and regulations promulgated thereunder.


                                        Yours very truly

                                        /s/  GOLDMAN, SPRING, SCHWARTZ & KICHLER