North Dakota Code § 28-01-07

Presumption against adverse possession of real estate
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In every action for the recovery of real property or for the possession thereof, the person 
establishing a legal title to the premises must be presumed to have been possessed thereof 
within the time required by law, and the occupation of such premises by any other person must 
be deemed to have been under and in subordination to the legal title, unless it appears that 

such premises have been held and possessed adversely to such legal title for twenty years 
before the commencement of such action.

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