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I also noticed this. It seems to be by design. The fileUpload renderer (in seam 2.0.1-GA) has the following line in the doEncodeEnd(...) method:
org.jboss.seam.ui.renderkit.FileUploadRendererBase.doEncodeEnd(ResponseWriter writer, FacesContext context, UIComponent component)
HTML.renderHTMLAttributes(writer, component, HTML.INPUT_FILE_PASSTHROUGH_ATTRIBUTES_WITHOUT_DISABLED);
So it seems the "disabled" attribute is ignored on purpose. Does anyone know of a specific reason why this is the case?