Court of Salerno, decree of 20 May 2026 (R.G. 00000756/2026)

The special proceedings for the assessment of the expenses and fees of arbitrators under art. 814, para. 2, of the Code of Civil Procedure apply exclusively to arbitration and are not extendable, even by analogy, to contractual arbitration (arbitrato irrituale), since the latter lacks the capacity to become a judgment upon the filing of the award. The fees owed to contractual arbitrators constitute a debt arising from mandate, for the enforcement of which ordinary proceedings on the merits may be brought.