South Dakota Code § 12-22-20

Certiorari to review recount as alternative remedy--Consolidation of proceedings
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Whenever any person entitled to commence certiorari proceedings to review any recount under chapter
12-21
also desires to institute a contest under §§
12-22-1
to
12-22-28
, inclusive, he may resort to both remedies, and such remedies shall be deemed consistent and concurrent. The court may, in such a case, order the consolidation of such proceedings.

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