28-01-11. Acts constituting adverse possession not based upon a written instrument

28-01-11. 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.