Court of Fermo, judgment of 11 September 2026, No. 427

A contractual award, the product of contractual arbitration (arbitrato irrituale), does not produce the effects of a judgment under art. 824-bis cod. proc. civ. and cannot be enforced by means of the procedure set out in art. 825 cod. proc. civ., the decree of enforceability being reserved to arbitral awards.
Execution undertaken on the strength of a contractual award is unlawful for want of an enforceable title, and it is immaterial that the correctness of the determinations embodied in the award has been established in separate proceedings.