EXHIBIT 5.11

                     [PEREZ BUSTAMANTE & PONCE LETTERHEAD]

                                                            Quito, March 5, 2004

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 Subordinated 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 Subordinated Notes due
2012 (the "Old Notes"), as described in the Registration Statement on Form F-4
(File No. 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 guarantors, 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 LETTERHEAD]

      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 indenture 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 indenture; and (iv) that the execution, delivery and performance of
the indenture does not violate or conflict with the Company's by-laws or the
laws of Ecuador; and (v) the indenture has been duly executed on behalf of the
Company by the duly authorized person and delivered.


      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 and making reference to our name under the caption "legal
matters" in the prospectus included therein. 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. Dewey
Ballantine LLP may rely on our opinion with respect to matters of the laws of
Ecuador for purposes of its opinion filed as an exhibit to the registration
statement, as if our opinion has been addressed to it.

                                            Very truly yours,


                                          /s/ Raul de la Torre
                                              ----------------------------------
c                                             Raul de la Torre