42-2-417 . Grounds for court to set aside relinquishment and consent. (1) The court shall set aside a relinquishment and consent to adopt if the individual who executed the relinquishment and consent establishes: (a) by clear and convincing evidence, before a decree of adoption is issued, that the consent was obtained by fraud or duress; or (b) by a preponderance of the evidence, that a condition permitting revocation has occurred, as expressly provided for in 42-2-411 . (2) A verbatim record of testimony must be made.
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