This suggests that Member States may end up having to raise two distinct legal actions: a more procedurally - oriented action challenging the authorizing act and a more substantive challenge to the legality of the resulting legislative measure. (europeanlawblog.eu)
The New York Convention «envisions multiple proceedings that address the same substantive challenge to an arbitral award» — but a primary jurisdiction situs is generally thought of to have more say in the vacatur / enforcement process. (blog.internationalpractice.org)
The court supported Bank Mellat's procedural as well as substantive challenge against HM Treasury. (lawyer-monthly.com)