HARWELL HOWARD HYNE GABBERT & MANNER, P.C. 1800 FIRST AMERICAN CENTER 315 DEADERICK STREET NASHVILLE, TENNESSEE 37238-1800 ------------------------------------- TELEPHONE (615) 256-0500 FACSIMILE (615) 251-1059 August 10, 1998 National HealthCare Corporation 100 Vine Street Murfreesboro, Tennessee 37130 Ladies and Gentlemen: We have acted as special counsel to National Healthcare Corporation. (the "Company") in connection with the registration of the Company's 1997 Stock Option and Stock Appreciation Rights Plan pursuant to a registration statement on Form S-8, as filed with the Securities and Exchange Commission (the "Registration Statement"). This firm hereby consents to the filing of this opinion as an exhibit to the Registration Statement and with agencies of such states and other jurisdictions as may be necessary in the course of complying with the laws of such states and jurisdictions regarding the offering and sale of the stock in accordance with the Registration Statement. We have examined originals, or certified or photostatic copies of such statutes, records, regulations, certificates of the officers of the Company and of public officials, and such other information as we have deemed necessary for purposes of rendering this opinion. In stating our opinion, we have assumed: (i) that all signatures are genuine, all documents submitted to us as originals are authentic, and all documents submitted to us as copies conform to authentic original documents; and (ii) that the parties to such documents have the legal right and power under all applicable laws, regulations and agreements to enter into, execute, deliver and perform their respective obligations thereunder. On the basis of such review, but subject to the limitations expressed herein, we are of the opinion, as of the date hereof, that the securities being registered by the Registration Statement will, when sold as contem- plated under the Registration Statement, be legally issued, fully paid and non- assessable. Our opinion herein is limited solely to the laws of the United States of America and the corporate law of the State of Delaware. In rendering the opinion set forth herein, we have relied upon the documents referenced above and have made no independent verification or investigation of factual matters pertaining thereto or to the Company. The opinion expressed herein is subject to applicable bankruptcy, insolvency, reorganization, moratorium, fraudulent conveyance and other similar laws now or hereafter in effect relating to or affecting the rights of creditors generally, judicial discre- tion, and equitable principles whether applied pursuant to a proceeding at law or in equity; and no opinion is expressed with respect to the availa- bility of equitable remedies. Very truly yours, HARWELL HOWARD HYNE GABBERT & MANNER, P.C.