After an award has been made, and announced, the submission and award cease to be revocable at the arbitrary will of either of the parties thereto;1 and this rule has been extended to cases in which the award has been determined upon by the arbitrators, and the defeated party, on learning of the result of the arbitration, has sought to revoke his submission.2 After the award has been made, the original claim is discharged and no action can be brought thereon,3 except for the specific ground of attack which will be discussed hereafter. While arbitration when complete is usually treated as a discharge of the original cause of action for the purpose of preventing an action thereon, the same principle applies to cases in which it is sought to use as a defense the facts which have already been submitted to arbitration and which have been decided adversely to the party who seeks to make such use of them. Such facts can not be used as a defense,4 since the arbitration when complete is conclusive as between the parties, unless it is attacked successfully for some specific ground. Since arbitration is informal in its nature, and since bad faith will not be imputed, it is said that reasonable presumption will be made in favor of the award.5 An award can not be attacked for mere difference of opinion on the part either of the defeated party or of the court,6 or for irregularities and informalities which do not prevent a fair hearing and award.7

2 England. Vynior's Case, 8 Coke, 81b; Mitchell v. Harris, 2 Ves. Jr. 129; Livingston v. RalH, 5 El. & Bl. 132.

Iowa. Read v. State Insurance Co., 103 Ia. 307, 64 Am. St. Rep. 180, 72 N. W. 666.

Massachusetts. Nute v. Hamilton Mutual Ins. Co., 72 Mass. (6 Gray) 174.

New York. Haggart v. Morgan, 5 N. Y. 422, 55 Am. Dec. 350.

Vermont. Mead v. Owen, 83 Vt. 132, 74 Atl. 1058.

West Virginia. Kinney v. Baltimore & Ohio Employes' Relief Association, 35 W. Va. 385, 15 L. R. A. 142, 14 S. E. 8.

Contra, apparently, Tattersall v. Groote, 2 B. & P. 131.

3 See Sec. 1145.

4 See Sec. 1136 et seq.

5Smith v. Seitz, 87 Conn. 678, 89 Atl. 257: Pond v. Harris, 113 Mass. 114; Miller v. Junction Canal Co., 53 Barb. (N. Y.) 500; Hawley v. Hodge, 7 Vt. 237.

See also, Union Insurance Co. v. Central Trust Co., 157 N. Y. 633, 44 L. R. A. 227, 52 N. E. 671.

6 Street v. Rigby, 6 Ves. 815; Bruna-don v. Board, 1 Cab. & E. 272; Munson v. Straits of Dover S. S. Co., 99 Fed. 787 [affirmed, Munson v. Straits of Dover S. S. Co., 102 Fed. 926]; Aktiesel-skabet Korn-og Foderstof Kompagniet v. Rederiaktiebolaget Atlanten, 250 Fed. 935.

7 Munson v. Straits of Dover S. S. Co., 99 Fed. 787 [affirmed, Munson v. Straits of Dover S. S. Co., 102 Fed. 926].

See on this question, Tattersall v. Groote, 2 B. & P. 131.

1 United States. N. P. Sloan Co. v. Standard Chemical & Oil Co., 256 Fed. 451.

Iowa. Turner v. Hartford Fire Ins. Co., - Ia. - 172 N. W. 166.

Nebraska. Connecticut Fire Ins. Co. v. O'Fallon, 49 Neb. 740, 69 N. W. 118; Schlanbusch v. Schlanbusch, 102 Neb. 462, 167 N. W. 557.