The discussion of the Working Group centred around two variant drafts of the provision concerning refusal of recognition or enforcement. The two initial variants of article 17 bis considered the discretion of the courts in granting interim measures of protection. Initial Variant 1 set out six exceptions to a principle of enforcement upon application to the courts, and was drafted in terms of ‘the court shall enforce, unless …’, intended to establish an obligation to enforce if prescribed conditions based on article 36 of the Model Law and article V of the New York Convention were met. A comparison had previously been drawn with the New York Convention, which also limits the reasons for which recognition and enforcement can be refused – although the requirement to enforce under the Convention does not extend to interim measures.