Attached files

                                                                     Exhibit 5.1

                     [LETTERHEAD OF SYNERGY LAW GROUP LLC]


                                February 13, 2014

VIA ELECTRONIC TRANSMISSION

Securities and Exchange Commission
100 F Street, N. E.
Washington, DC  20549

Re: Asiya Pearls, Inc.
    Form S-1 Registration Statement

Ladies and Gentlemen:

     We have acted as counsel to Asiya Pearls,  Inc., a Nevada  corporation (the
"Company"), and refer to the above-captioned  registration statement on Form S-1
(the "Registration Statement") under the Securities Act of 1933, as amended (the
"Act") filed by the Company with the Securities and Exchange Commission.

     We have  examined the  originals,  photocopies,  certified  copies or other
evidence of such records of the Company, certificates of officers of the Company
and  public  officials,  and other  documents  as we have  deemed  relevant  and
necessary as a basis for the opinion hereinafter expressed. In such examination,
we have assumed the  genuineness  of all  signatures,  the  authenticity  of all
documents   submitted  to  us  as  certified   copies  or  photocopies  and  the
authenticity of the originals of such latter documents.

     Based on our  examination  mentioned  above, we are of the opinion that the
5,000,000  shares of common  stock being  offered  pursuant to the  Registration
Statement  are duly  authorized  and will be,  after  subscription  for and when
issued in the  manner  described  in the  Registration  Statement,  legally  and
validly issued, fully paid and non-assessable.

     We hereby consent to the prospectus  discussion of this opinion, the filing
of this opinion as Exhibit 5.1 to the Registration  Statement and being named in
the Registration  Statement.  In giving the foregoing consent,  we do not hereby
admit that we are in the  category of persons  whose  consent is required  under
Section  7 of the Act,  or the  rules  and  regulations  of the  Securities  and
Exchange Commission.

                                      Very truly yours,


                                      /s/ Synergy Law Group LLC
                                      --------------------------------------
                                      Synergy Law Group, LLC



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