EXHIBIT 5.11


                         (PEREZ BUSTAMANTE & PONCE LOGO)

                                                Quito, November 27, 2002


BURNS PHILP ECUADOR S.A.
QUITO.- ECUADOR



Ladies and Gentlemen:

             Re: 9-3/4% Series B Senior Subordinated Notes Due 2012

      We have acted as special ECUADORIAN counsel to BURNS PHILP ECUADOR S.A.,
an ECUADORIAN corporation (the "Company"), in connection with the offer to
exchange (the "Exchange Offer") by Burns Philp Capital Pty Limited, an
Australian corporation (the "Issuer") and wholly owned subsidiary of Burns,
Philp & Company Limited ("Burns Philp"), of U.S.$400,000,000 aggregate principal
amount of 9-3/4% Series B Senior Notes due 2012 (the "Exchange Notes") which are
being registered under the Securities Act of 1933, as amended (the "Securities
Act"), for its existing 9-3/4% Senior Notes due 2012 (the "Old Notes"), as
described in the Registration Statement on Form F-4 (File N(degree)333-98141)
relating to the Exchange Offer (as amended or supplemented, the "Registration
Statement"), initially filed with the United States Securities and Exchange
Commission on August 9, 2002. The Old Notes were issued, and the Exchange Notes
are proposed to be issued, under an indenture dated as of June 21, 2002 (the
"Indenture"), among the Issuer, Burns Philp and certain subsidiaries of Burns
Philp (together with the Company, the "Subsidiary Guarantors") and The Bank of
New York, a New York banking corporation, as Trustee (the "Trustee"). The terms
of the Exchange Notes to be issued are substantially identical to the Old Notes,
except for certain transfer restrictions and registration rights relating to the
Old Notes. The Old Notes are, and the Exchange Notes will be, fully and
unconditionally guaranteed by the Company and the Subsidiary Guarantors on a
senior subordinated basis (the "Guarantees"). The Indenture is an exhibit to the
Registration Statement.

      We have examined originals, or copies certified or otherwise identified to
our satisfaction, of the Indenture, the supplemental indenture of additional
subsidiary guarants, and the minutes of the board of meeting of the company
dated November 25, 2002, ( the "Relevant Documents"), as in our judgment are
necessary or appropriate to enable us to render the opinion expressed below. In
rendering such opinion, we have relied as to factual matters upon the
representations, warranties and other statements made in the Relevant Documents.

                         (PEREZ BUSTAMANTE & PONCE LOGO)


      In our examination, we have assumed, (i) the genuineness of all signatures
(ii) the legal capacity of all natural persons, (iii) the authenticity of all
documents submitted to us as originals, and (iv) the conformity to the original
documents of all documents submitted as conformed, facsimile or photostatic
copies.

      Based upon the foregoing, and subject to the exceptions, qualifications,
limitations and assumptions herein set forth, we are of the opinion that (i) the
execution and delivery of, and the performance by the Company of its obligations
under, the Guarantee has been duly authorized by all requisite corporate action
on the part of the Company; and (ii) the Company is validly incorporated and of
good standing; and (iii) that the Company has full power and authority, and all
necessary consents and approvals to execute, deliver and perform its obligations
under the Guarantee; and (iv) that the execution, delivery and performance of
the Guarantee does not violate or conflict with the Company's by-laws or the
laws of Ecuador.

      In rendering the foregoing opinion, we express no opinion, directly or
indirectly, as to laws other than the laws of THE REPUBLIC OF ECUADOR. The
foregoing opinion is rendered as of the date hereof and we assume no obligation
to update such opinion to reflect any facts or circumstances which may hereafter
come to our attention or any changes in the law which may hereafter occur.

      We hereby consent to the filing of this opinion as an Exhibit to the
Registration Statement. In giving such consent, we do not thereby admit that we
come within the category of persons whose consent is required under Section 7 of
the Securities Act of 1933, as amended, or the rules and regulations of the
Securities and Exchange Commission thereunder.

                                        Very truly yours,

                                        /s/ Raul de la Torre
                                        Raul de la Torre