Section 2(1)(b) in The Orissa Prevention of Land Encroachment Rules, 1985
(b)"Encroacher" means a person who unauthorisedly -(i)occupies any land as defined under Clause (d), or(ii)obstructs by dumping earth or any other materials, rubbish or filth on it, or(iii)puts any fence around it, or(iv)takes up any construction or cultivation on it -