ANSLOW & JACLIN, LLP
COUNSELORS AT LAW

February 6, 2004

Combined Opinion and Consent

Championlyte Holdings, Inc.
3450 Park Central Blvd.
N. Pompano Beach, Florida 33064

RE:     CHAMPIONLYTE HOLDINGS, INC.


Gentlemen:

     You have requested our opinion, as counsel for Championlyte Holdings, Inc.
a Florida corporation (the "Company"), in connection with the registration
statement on Form SB-2 (the "Registration Statement"), under the Securities Act
of 1933 (the "Act"), being filed by the Company with the Securities and Exchange
Commission.

     The Registration Statement relates to an offering of 6,666,666 shares of
the Company's common stock, $0.001 par value, 43,206,507 shares sold by
enumerated selling shareholders and 1,076,400 shares of the Company's common
stock issuable in connection with the conversion of certain warrants and
options.

     We have examined such records and documents and made such examinations of
laws as we have deemed relevant in connection with this opinion. It is our
opinion that the shares of common stock to be offered pusuant to the
Registration Statement and sold by the selling shareholders have been duly
authorized and are legally issued, fully paid and non-assessable.

     No opinion is expressed herein as to any laws other than the State of
Florida of the United States. This opinion opines upon Florida law including
the statutory provisions, all applicable provisions of the Florida Constitution
and reported judicial decisions interpreting those laws.

     We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the reference to our firm under the caption "Legal
Matters" in the Registration Statement. In so doing, we do not admit that we are
in the category of persons whose consent is required under Section 7 of the Act
and the rules and regulations of the Securities and Exchange Commission
promulgated thereunder.

Very truly yours,

ANSLOW & JACLIN, LLP

By:    /s/  Anslow & Jaclin, LLP
         ------------------------
            ANSLOW & JACLIN, LLP

            4400 Route 9 South, 2nd Floor, Freehold, New Jersey 07728
                    Tel: (732) 409-1212 Fax: (732) 577-1188