[LOGO AND LETTERHEAD OF APPLEBY, SPURLING & KEMPE]






                                       13th June, 1996



American Craft Brewing International Limited
Cedar House
41 Cedar Avenue
Hamilton HM 12
Bermuda



Dear Sirs:


                   Re: Offering of Shares of Common Stock
                   --------------------------------------

    We have been requested  by  American Craft  Brewing International Limited, a
Bermuda exempted company (the "Company"), to provide this  opinion in connection
with its proposed offering (the "Offering") of 1,333,333 shares  of common stock
in the  Company  of par value US$0.01 each and 1,333,333 redeemable common stock
purchase  warrants  (together  the  "Securities")  pursuant  to  a  registration
statement on Form S-1 which is to be filed with the United States Securities and
Exchange  Commission under the  United  States Securities Act 1933 as amended on
14th June, 1996 (the "Registration Statement").

    We have examined the Memorandum of Association and  Bye-Laws of the Company,
a draft  of  the Registration  Statement  dated  6th  June, 1996  and such other
corporate records and documents as  we have deemed necessary as a basis for this
opinion.  We have not reviewed any resolutions adopted by the Board of Directors
of the  Company  relating to the Offering.  In such examination, we have assumed
the  genuineness  of  all  signatures  and  the  authenticity  of  all documents
submitted  to us  as  originals  and the  conformity  with the  originals of all
documents submitted to us as copies.

    Based upon  the  foregoing, it is  our  opinion  that  the  Company  has the
corporate  power to  make  the  Offering  as  contemplated  in  the Registration
Statement.

    No  opinion  is expressed  herein as to  any laws other than the laws of the
Islands of Bermuda.







                                       -2-


    We  hereby  consent  to  the  references to  our  name  in  the Registration
Statement and to the filing of this opinion as  an  exhibit to  the Registration
Statement.




                                       Yours faithfully,



                                       APPLEBY, SPURLING & KEMPE