Court of Tempio Pausania, judgment of 7 April 2026, No. 164

A clause in the articles of an association providing for the referral of disputes to a board of arbiters (probiviri) who shall decide according to equity and without procedural formalities does not amount to an arbitration clause within the meaning of Article 808 of the Code of Civil Procedure, but serves as an internal dispute-resolution mechanism constituting a form of mediation or negotiation that does not preclude access to the ordinary courts.