EXHIBIT 5.1

                                JAMES J. MULLIGAN
                                 ATTORNEY AT LAW
                               812 TIMBERLAKE COURT              (937) 298-2226
                                DAYTON, OHIO 45429                    FAX: SAME





                               September 17, 2002



Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street N.W.
Washington DC 20549

Gentlemen:

         As counsel, I have assisted SunLink Health Systems, Inc., an Ohio
corporation ("SunLink"), in connection with the preparation and filing of
SunLink's Registration Statement on Form S-8 relating to the offering and sale
of up to 810,000 of its Common Shares, without par value, pursuant to its 2001
Long Term Stock Option Plan (the "Plan").

         Please be advised that I have examined such proceedings and records of
SunLink and have made investigation of such other matters as in my judgment
permits me to render an informed opinion on the matters set forth herein. Based
upon the foregoing, it is my opinion that:

                  (i)      SunLink is a corporation duly organized, validly
         existing and in good standing under the laws of the State of Ohio, with
         full power to issue and sell its Common Shares pursuant to the Plan;
         and

                  (ii)     Common Shares of SunLink issued or sold by SunLink
         pursuant to the Plan have been duly authorized and, when issued or sold
         and paid for in accordance with the terms of the Plan, will be legally
         issued, fully paid and non-assessable.

     I consent to the use of this opinion as an exhibit to SunLink's
Registration Statement on Form S-8 with respect to the Plan and the Common
Shares issued thereunder.

                                Very truly yours,

                              /s/ James J. Mulligan