North Dakota Code § 9-12-05

Partial performance - Extinction pro tanto
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A partial performance of an indivisible obligation extinguishes a corresponding proportion 
thereof if the benefit of such performance is retained voluntarily by the creditor, but not 
otherwise. If such partial performance is of such a nature that the creditor cannot avoid retaining 
it without injuring the creditor's own property, the creditor's retention thereof is not presumed to 
be voluntary.

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