What Happens at the Seat, Stays at the Seat? Nagaraj and Transnational Issue Estoppel under the New York Convention
The Supreme Court's decision in Nagaraj V. Mylandla v. PI Opportunities Fund-I is the clearest judgment of the Supreme Court of India recognising and applying the doctrine of transnational issue estoppel in proceedings for the enforcement of a foreign arbitral award. Its significance, however, extends beyond the...