Made this even clearer: 
https://github.com/arangodb/arangodb/commit/1f0ecf9462fb442e6cd9acfcdc156b573bc7bf46

The "closest" documents are returned first. The limit parameter of NEAR() 
does not change this overall behavior. Only if there are multiple documents 
with the same distance around the maximum number of results, it is unclear 
which of them will be chosen.
E.g. there are 3 documents with distance 260.347, 99 other are closer and 
the limit is 100. One non-deterministically chosen document of the 3 will 
be included in the result so that there are 100 records in the result set. 
A later query may return a different document out of the 3 than on an 
earlier run.

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