Transnational Issue Estoppel in Foreign Arbitral Awards: What the Supreme Court Just Decided The doctrine of Transnational Issue Estoppel in Foreign Arbitral Awards finally has a home in Indian jurisprudence. For years, losing parties in international arbitration had a quiet escape route exhaust remedies at the seat, then walk into an Indian court and reframe the same losing argument as a "public policy" violation. The Supreme Court, in Nagaraj V. Mylandla v. PI Opportunities