Acts constituting adverse possession under claim other than written instrument or judgment

For the purpose of constituting an adverse possession by a person claiming title not founded upon a written instrument, or judgment, or decree, land shall be deemed to have been possessed and occupied in the following cases only: (1) Where it has been protected by a substantial inclosure; or (2) Where it has been usually cultivated or improved. Source: SDC 1939 & Supp 1960, § 33.0224.