Nagaraj marks a significant step in favour of the enforcement of foreign arbitral awards in India by recognising transnational issue estoppel and limiting the re-litigation of issues already adjudicated by the seat court.

The Shashoua judgment represents a watershed moment in the evolution of Section 48 public policy jurisprudence, particularly in its application to complex shareholders dispute arbitration. The court’s sophisticated analysis validates contractual deadlock resolution mechanisms while maintaining necessary boundaries between arbitral authority and statutory regulation.