White & Case
         W. Jurcewicz i Wspolnicy - Kancelaria Prawna Spolka Komandytowa
                              Ul. Marszalkowska 142
                                  00-061 Warsaw
                                     Poland

                                                                    26 June 2009

The State Treasury of The Republic of Poland
Ministry of Finance
Ul. Swietokrzyska 12
Warsaw, Poland

Dear Sirs,

We have acted as Polish counsel to the State Treasury of the Republic of Poland
(the "State Treasury") in connection with the preparation of the Amendment to
the Registration Statement under Schedule B filed with the United States
Securities and Exchange Commission on even date herewith (the "Registration
Statement"), pursuant to which the State Treasury proposed from time to time to
issue and sell its notes and bonds as described therein (the "Securities").
Terms used herein and defined in the Registration Statement are used herein as
so defined.

In order to give the opinion hereinafter set forth, we have examined the
following:

(a)   the Public Finance Law of June 30, 2005 (as amended);

(b)   the Budget Act for 2009 of January 9, 2009 (as amended);

(c)   the Order of the Minister of Finance of June 26, 2006 on the conditions of
      issuing treasury bonds to be offered on foreign markets;

(d)   the Personal Income Tax Act of July 26, 1991 (as amended); and

(e)   the Corporate Income Tax Act of February 15, 1992 (as amended);

and such other laws as was deemed necessary for such purpose.

As to certain facts material to our opinion, we have relied to the extent that
we deemed such reliance proper upon statements of representatives of the State
Treasury. In rendering such opinion, we have assumed that any Securities issued
by State Treasury under the Registration Statement, when aggregated with any
other external debt securities issued by the State Treasury, will not exceed the
limits for the incurrence of external indebtedness in the form of bonds and
securities issued by the State Treasury pursuant to the provisions of the Budget
Act for 2009.
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Based upon the foregoing and subject to the assumptions set forth herein, we are
of the opinion that, upon the execution by the Minister of Finance of the letter
of issue, with respect to particular Securities, when duly authorized, executed
and delivered by the State Treasury, represented by the Minister of Finance,
authenticated in accordance with the provisions of a duly executed Fiscal Agency
Agreement and delivered to, and paid for by, the relevant underwriters or
purchasers thereof in the manner contemplated by the Registration Statement and
the relevant Underwriting Agreement, the Securities will be valid and legally
binding obligations of the State Treasury under the laws of Poland.

This opinion is limited to the laws of the Republic of Poland and does not cover
any questions arising under or relating to the laws of United States or the laws
of the State of New York, any political subdivision thereof or any other
jurisdiction.

We hereby consent to the filing of this opinion as an exhibit to the
Registration Statement and to the use of our name under the caption "Validity of
the Securities" in the Registration Statement. In giving such consent we do not
thereby admit that we are in the category of persons whose consent is required
under Section 7 of the Securities Act of 1933, as amended.

Very truly yours,


/s/ Witold Danilowicz
--------------------------
Managing Partner
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