The term «arbitral procedure» encompasses the period beginning with the filing of an action and ending when the award is rendered.891 The application of the law by a tribunal, on the other hand, goes to the actual merits of a dispute and therefore falls outside the scope of review at the recognition and enforcement stage.892 (newyorkconvention1958.org)
It merely insists that the challenge to the court's jurisdiction be brought in that court and not raised for the first time at the enforcement stage. (slaw.ca)
All Canadian courts are deemed at the enforcement stage to have taken judgment properly. (slaw.ca)