Exhibit 31

ORIENT-EXPRESS HOTELS LTD.

Rule 13a-14(a)/15d-14(a) Certification

I, James B. Sherwood, Chairman of Orient-Express Hotels Ltd., certify that:

1.    I
have reviewed this quarterly report on Form 10-Q of Orient-Express Hotels Ltd. for the quarter ended September 30, 2004;

2.    Based
on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the
circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.    Based
on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of
operations and cash flows of the registrant as of, and for, the periods presented in this report;

4.    The
registrant's other certifying officers and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange Act
Rules 13a-15(e) and 15d-15(e)) for the registrant and we have:



5.    The
registrant's other certifying officers and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the registrant's auditors and the
audit committee of the registrant's board of directors (or persons performing the equivalent function):



|Dated: November 9, 2004 |  |                                                                         
|----------------------- |  | ------------------------------------------------------------------------
|                        |  | /s/ J.B. SherwoodJames B. Sherwood
Chairman
(Co-Chief Executive Officer)

32

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ORIENT-EXPRESS HOTELS LTD.

Rule 13a-14(a)/15d-14(a) Certification

I, Simon M.C. Sherwood, President of Orient-Express Hotels Ltd., certify that:

1.    I
have reviewed this quarterly report on Form 10-Q of Orient-Express Hotels Ltd. for the quarter ended September 30, 2004;

2.    Based
on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the
circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.    Based
on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of
operations and cash flows of the registrant as of, and for, the periods presented in this report;

4.    The
registrant's other certifying officers and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange Act
Rules 13a-15(e) and 15d-15(e)) for the registrant and we have:



5.    The
registrant's other certifying officers and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the registrant's auditors and the
audit committee of the registrant's board of directors (or persons performing the equivalent function):



|Dated: November 9, 2004 |  |                                                                              
|----------------------- |  | -----------------------------------------------------------------------------
|                        |  | /s/ S.M.C. SherwoodSimon M.C. Sherwood
President
(Co-Chief Executive Officer)

33

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ORIENT-EXPRESS HOTELS LTD.

Rule 13a-14(a)/15d-14(a) Certification

I, James G. Struthers, Vice PresidentFinance and Chief Financial Officer of Orient-Express Hotels Ltd., certify that:

1.    I
have reviewed this quarterly report on Form 10-Q of Orient-Express Hotels Ltd. for the quarter ended September 30, 2004;

2.    Based
on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the
circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.    Based
on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of
operations and cash flows of the registrant as of, and for, the periods presented in this report;

4.    The
registrant's other certifying officers and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange Act
Rules 13a-15(e) and 15d-15(e)) for the registrant and we have:



5.    The
registrant's other certifying officers and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the registrant's auditors and the
audit committee of the registrant's board of directors (or persons performing the equivalent function):



|Dated: November 9, 2004 |  |                                                                                        
|----------------------- |  | ---------------------------------------------------------------------------------------
|                        |  | /s/ J.G. StruthersJames G. Struthers
Vice PresidentFinance
and Chief Financial Officer

34

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