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                                                                     EXHIBIT 5.1

   
                              Harry B. Sands & Co.
                                 P.O. Box N-624
                                 Nassau, Bahamas
    

                                                                   22 March 1999

Steiner Leisure Limited
Suite 104A,
Saffrey Square,
Nassau, The Bahamas

Dear Sirs,

   
                      RE: FORM S-3 REGISTRATION STATEMENT
    
   

We have acted as Bahamian counsel to Steiner Leisure Limited, a company
incorporated under the laws of the Commonwealth of The Bahamas ("the Company"),
in connection with a Registration Statement on Form S-3 (No. 333-73363) ("the
Registration Statement") filed with the Securities and Exchange Commission under
the Securities Act of 1933 ("the Act"), as amended, for the registration of up
to 1,725,000 common shares of $.01 par value, of the Company being sold by the
Selling Shareholder (as defined in the Registration Statement) ("the Selling
Shareholder Shares"). Pursuant to an underwriting agreement ("the Underwriting
Agreement") by and among the Company, the Selling Shareholder and the
underwriters named in the Registration Statement ("the Underwriters") the
Underwriters have agreed to purchase the Selling Shareholder Shares from the
Selling Shareholder.
    

In that connection, we have examined originals, or copies certified or 
otherwise identified to our satisfaction, of such documents, corporate records 
and other instruments as we have deemed necessary for the purpose of this 
opinion, including the current Memorandum and Articles of Association of the 
Company.

Based on the forgoing, we are of the opinion, as follows:

      1.   The Company is a validly existing corporation under the laws of the
           Commonwealth of The Bahamas; and

   
      2.   The Selling Shareholder Shares have been validly issued to the
           Selling Shareholder as fully paid and non-assessable. 
    
 
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OPINION LETTER                                             22 MARCH, 1999
                                     Page 2

   
    


This opinion is limited to the laws of the Commonwealth of The Bahamas at the
date of this opinion, and no opinion is expressed to the laws of any other
jurisdiction other than that of the Commonwealth of The Bahamas.

   
We hereby consent to the filing of this opinion as part of the Registration
Statement and to the use of our name therein and in the Prospectus under the
captions "Risk Factors--We are not a United States Company and, as a Result, 
There are Special Risks," "Taxation--Certain Bahamian and Other Tax 
Considerations" and "Legal Matters".

    

                              Yours faithfully,
                              HARRY B. SANDS & COMPANY

                              /s/ ARTHUR SELIGMAN
                              ------------------------
                                  Arthur Seligman