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> XPath says that nodes should be returned in 'document order', which
> becomes a non-trivial in the case of some expressions involving
> the union operator.
Actually, XPath nowhere says that nodes must be returned in document order.
Node-sets are sets; they have no order. Whether you want to subsequently
process the nodes in document order or not is up to the external framework
(e.g. XSLT). I could certainly imagine frameworks that don't require
document-order processing. In the end, the distinction isn't all that
helpful, because XPath alone doesn't define any conformance requirements.
There is no required (or specified) behavior for an XPath processor, because
XPath just defines abstract objects rather than implementable behavior.