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Critically evaluate the incorporation into the New York Convention of the restriction that only the courts of the seat of an arbitration can annul an award. Are the policies of the Convention served by this limitation, and what would be the consequences if no such limitation existed?

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Critically compare the doctrines of competence-competence adopted by American and French courts. Which is superior?

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Should arbitral awards annulled at the seat of the arbitration be enforced by the courts of other countries?

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