North Dakota Code § 28-01-11

Acts constituting adverse possession not based upon a written instrument
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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.

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