Failure to comply with §§ 25-5A-22 to 25-5A-24 , inclusive, may not be considered a basis for setting aside a voluntary termination of parental rights or an adoption. Source: SL 1994, ch 197 , § 4.
Failure to receive counseling
SDCL § 25-5A-25 — under VOLUNTARY TERMINATION OF PARENTAL RELATIONS.
SDCL § 25-5A-25