ANSLOW & JACLIN, LLP
COUNSELORS AT LAW

September 29, 2003

Combined Opinion and Consent

Championlyte Holdings, Inc.
2999 NE 191st Street, Penthouse 2
North Miami Beach, Florida 33180

RE:     CHAMPIONLYTE HOLDINGS, INC.

Gentlemen:

We have acted as counsel to Championlyte Holdings, Inc., a Florida corporation
(the "Company"), in connection with the preparation and filing with the
Securities and Exchange Commission (the "Commission") under the Securities Act
of 1933 as amended (the "Act") of the Company's Registration Statement on Form
S-8, filed contemporaneously with the Commission relating to the registration
under the Act of 6,666,667 shares (the "Shares") of the Company's Common Stock,
$0.001 par value (the "Common Stock").

In rendering this opinion, we have reviewed the Registration Statement on Form
S-8, as well as a copy of the Certificate of Incorporation of the Company, as
amended, and the By-Laws of the Company. We have also reviewed such statutes and
judicial precedents as we have deemed relevant and necessary as a basis for the
opinion hereinafter expressed. In our examination, we have assumed the
genuineness of all signatures, the legal capacity of natural persons, the
authenticity of all documents submitted to us as originals, the conformity with
the original documents of all documents submitted to us as certified or
photostatic copies, and the authenticity of the originals of such copies.

Based on the foregoing and in reliance thereon, and subject to the
qualifications and limitations set forth herein, we are of the opinion that:

(1)      The Company has been duly incorporated and is a validly existing
         corporation under the laws of the State of Florida;

(2)      The Shares, when issued in connection with the agreements (copies
         annexed to the Registration Statement), will be legally issued, fully
         paid and non-assessable.

This opinion is limited to the General  Corporation Law and the  Constitution of
the State of Florida and we express no opinion  with  respect to the laws of any
other  jurisdiction.  We consent to your filing this opinion with the Securities
and Exchange Commission as an exhibit to the Registration Statement on Form S-8.
This opinion is not to be used, circulated,  quoted or otherwise referred to for
any other purpose without our prior written consent.

Very truly yours,

ANSLOW & JACLIN, LLP

By:    /s/  Anslow & Jaclin, LLP
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