Can a consent judgment be delivered in the presence of the parties?

In Coates v. Coates, the action was for the rents and profits of lands. A settlement between the parties was reached by which, amongst other terms, the defendant granted to the plaintiff his interest in the lands. When the case was called for trial, counsel for the defendent appeared and informed the court that a settlement had been reached, but without giving the details. An entry was then made in the minute book that the case was "settled out of court". Subsequently the defendent refused to perform and the plaintiff sued for specific performance of the settlement agreement. The defendant sought refuge in the statute as no memorandum in writing had been made. Judgment went for the plaintiff on the ground of part performance, the court assuming without discussion that the statute was applicable to the settlement agreement. Its applicability to a consent judgment delivered in court in the presence of the parties did not arise for discussion.