N.D. Cent. Code § 28-01-12: When possession of tenant presumed to be possession of landlord

Whenever the relation of landlord and tenant has existed, the possession of the tenant must be deemed the possession of the landlord, until the expiration of twenty years from the termination of the tenancy, or, when there has been no written lease, until the expiration of twenty years from the time of the last payment of rent, notwithstanding that such tenant may have acquired another title or may have claimed to hold adversely to the tenant's landlord. Such presumptions may not be made after the periods herein limited.