<p>In this paper, we investigate the motion of wheeled mobile robots on rough terrains modelled as noisy nonholonomic constraints. Such constraints are the natural extension of ideal nonholonomic constraints when the Stratonovich process is directly introduced in the constraint equations. The resulting stochastic model can capture motion on rough surfaces, random skip/uncertainty in the wheel-ground point of contact, or stochastic motion of the surface. We study a differential robot with ideal noisy and affine noisy constraints, where each case models a certain aspect of motion on rough terrains. We then qualitatively investigate their corresponding stochastic dynamics through Monte-Carlo simulations. The proposed stochastic model for roving rough terrains has the potential to serve as the process model in model-based motion estimators relying on measurements from an interoceptive suite of sensors. The challenge will be dealing with the nonlinear appearance of the noise in the equations of motion. </p>