By allowing, notwithstanding the strict letter of the law, that the orders issued by the “juge d’appui” (state court intervening in the context of an ongoing arbitration) may be the subject of further judicial recourse where the judge has exceeded his powers, case law has created a conflict between the principle of efficiency which is characteristic of contemporary arbitration law, and the principle of the subsidiarity of the State courts’ powers in this respect. The situation is all the more problematic in that reconciling these principles is a major issue when the effect of res judicata resulting from orders issued by the “juge d’appui” prevents, according to case law, them from being challenged before the court considering an application for annulment, which is in stark contrast with the decisions rendered in the context of institutional arbitration. The current state of the law appears unsatisfactory, as a result of which alterations could no doubt be envisaged to the principle whereby there should be no judicial challenge to the decisions of the “juge d’appui”.