At least in case of EclipseLink 10g and 11g differ. Since 11g it is not recommended to use first_rows hint for pagination queries.
See "Is it possible to disable jpa hints per particular query". Such a query should not be used in 11g.
SELECT * FROM (
SELECT /*+ FIRST_ROWS */ a.*, ROWNUM rnum FROM (
SELECT * FROM TABLES INCLUDING JOINS, ORDERING, etc.) a
WHERE ROWNUM <= 10 )
WHERE rnum > 0;
But there can be other nuances.