N.D. Cent. Code § 28-01-11 : — JUDICIAL PROCEDURE, CIVIL01 - TIME FOR COMMENCING ACTIONS —01-11 - Acts constituting adverse possession not based upon a written instrument

For the purpose of constituting an adverse possession by a person claiming title not founded upon a written instrument nor upon a judgment or decree, land shall be deemed to have been possessed and occupied only in the following cases:

1. When it has been protected by a substantial enclosure; or
2. When it has been usually cultivated or improved.

N.D.C.C. § 28-01-11

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