South Dakota Code § 32-3-6

Ownership passing by operation of law--Burden of proof
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If the ownership of any motor vehicle, trailer, or semitrailer passes by operation of law, judicial sale, repossession, or proceedings or in any other manner not provided for in this chapter, the owner may, upon furnishing satisfactory proof to the department of such ownership, procure a certificate of title to the motor vehicle, trailer, or semitrailer regardless of whether a certificate of title has ever been issued. The burden of such satisfactory proof shall be on the applicant.

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