McGuire Woods Battle & Boothe LLP One James Center 901 East Cary Street Richmond, Virginia 23219-4030 Telephone/TDD (804)775-1000 o Fax (804)775-1061 Direct Dial: (804) 775-4384 May 19, 1997 Markel Corporation 4551 Cox Road Glen Allen, VA 23060 Re: Markel Corporation Markel Capital Trust I Registration Statement on Form S-4 File No. 333-21663 Gentlemen: We have acted as special tax counsel for Markel Corporation ("Markel") and Markel Capital Trust I (the "Trust") in connection with the offer to exchange up to U.S. $150,000,000 of the Trust's 8.71% Series B Capital Securities which have been registered under the Securities Act of 1933, as amended, for a like Liquidation Amount of the Trust's outstanding 8.71% Series A Capital Securities. In rendering our opinion, we have examined the Amended and Restated Declaration of Trust (the "Declaration") and have assumed that the Issuer Trustees will conduct the affairs of the Trust in accordance with the Declaration. We hereby confirm the opinions described under the caption "Certain Federal Income Tax Consequences" in the prospectus (the "Prospectus") that is part of the Registration Statement on Form S-4 filed by Markel and the Trust with the Securities and Exchange Commission. Capitalized terms used herein but not defined have the meanings as provided in the Prospectus. We hereby consent to the use of our name under the caption "Certain Federal Income Tax Consequences" in the Prospectus. The issuance of such a consent does not concede that we are an "Expert" for purposes of the Securities Act of 1933. Very truly yours, /s/ McGuire, Woods, Battle & Boothe, L.L.P.