I guess I can see both sides of the argument, but it does seem a bit silly to think that a game could be absolute garbage and have amazing action elements propel it to best action game of the year. Its not like the award is singling out a specific scene...that would be different. If the award was for best action based segment, i.e. car chase, or final boss fight, it would be better imo. That way game of the year would have less of a confusing comparison.
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