Exhibit 8.4

                    [LETTERHEAD OF MALLESONS STEPHEN JAQUES]

                                                                November 3, 2003

BP Australia Capital Markets Limited
Level 29
The Tower
Melbourne Central
360 Elizabeth Street
Melbourne VIC 3000
Australia

Dear Sirs

BP Australia Capital Markets Limited - Registration Statement on Form F-3

We have acted as Australian counsel to BP Australia Capital Markets Limited in
connection with the offer of Guaranteed Debt Securities of the Debt Issuers as
described in the Registration Statement on Form F-3 ("Registration Statement")
filed by BP Group on or about the date of this letter under Rule 462(b) of the
United States Securities Act of 1933, as amended ("Securities Act"). We confirm
to you our opinion as set out in the Registration Statement under the caption
"Taxation Considerations - Australian Taxation" in relation to matters of
Australian tax law.

We consent to the use of our name and the filing of this letter as an exhibit to
the Registration Statement. In giving such consent, we do not admit that we are
in the category of persons whose consent is required under Section 7 of the
Securities Act.

Yours faithfully

/s/ Mallesons Stephen Jaques