Newsletter-21

192 NEWSLETTER 2016 New York Convention are applicable for set-aside proceedings to be initiated in Turkey. As a general remark, it may be concluded that most states restrict the set-aside challenges to excess of jurisdiction and lack of due process, which reflect the policies behind those grounds 6 . Conclusion Limitations on document production requests aim to find the right balance between the parties’ rights and various concerns. Having this in mind, the IBARules set forth the grounds for objection to document production requests, which may lead to the limited production of a document, or to non-production. These limitations may be challenged during set-aside or enforcement proceedings, by a party who could not obtain the desired result in its arbitration proceedings, and may cause that the arbitral award is rendered useless for the winning party. These challenges should be carefully reviewed and analyzed by the courts, in order not to permit abuse of the right to due process. 6 Redfern and Hunter on International Arbitration, §10.88.