Is trampling enough "improvement" to create a "highway"?

Recently, I found Highways - OpenStreetMap Wiki - There it says:

A highway in OpenStreetMap is any road, route, way, or thoroughfare on land which connects one location to another and has been paved or otherwise improved to allow travel by some conveyance, including motorised vehicles, cyclists, pedestrians, horse riders, and others (but not trains …).

Curiously, this does not allow for informal paths getting mapped as highway=*. Unless trampling is considered “improving” the ground. Can you agree?

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