Massachusetts Supreme Judicial Court September 4, 1906 (Nay v. Boston & Worcester Street Railway Co.)

Loring, J.

The parties to these two actions at law might have submitted to arbitration the matters in dispute between them by a submission in pais, a submission under the statute, or by a rule of court made in each action. If the first method of procedure had been adopted, the only way of enforcing the award would have been by an action on the award when made.