North Dakota Code § 47-10-01

Method of transfer
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An estate in real property, other than an estate at will or for a term not exceeding one year, 
can be transferred only by operation of law or by an instrument in writing, subscribed by the 
party disposing of the same or by the party's agent thereunto authorized by writing. This does 
not abridge the power of any court to compel the specific performance of any agreement for the 
sale of real property in case of part performance thereof.

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