Black's Law Dictionary 1295 (5th ed. 1979).        In re A.W., 241 Kan. 810, 740 P.2d 82 (1987), discusses K.S.A. 38-125. Although the case did not concern the precise issue at bar, the logical conclusion to be drawn from that case is that severance under K.S.A. 38-125 et seq. requires not only relinquishment and surrender by the parent but acceptance of the surrender by SRS.

Under Kansas statute the relinquishment of parental rights must be knowing, free, and voluntary. In re A.W. , 241 Kan. 810, 816, 740 P.2d 82 (1987). The district court has the power to approve a parent's relinquishment once it determines that the relinquishment is voluntary and the district court has fully advised the parent of all rights and consequences.

In re P.R. , 2019 WL 2306763, at *4. The panel's citation to In re A.W ., 241 Kan. 810, 816-17, 740 P.2d 82 (1987), does not support such a broad statement. Rather, when our courts have interpreted statutes affecting the right to parent, they have generally done so in a strict manner.

"[T]he termination of parental rights is an extremely serious matter and may only be accomplished in a manner which assures maximum protection to all of the rights of the natural parents and of the child involved." In re A.W., 241 Kan. 810, 814, 740 P.2d 82 (1987). Our Supreme Court has recognized that there are three statutory methods for termination of parental rights: (1) adoption; (2) termination of parental rights; and (3) relinquishment of rights.

Moreover, as the Court of Appeals noted, "the termination of parental rights is an extremely serious matter and may be accomplished only in a manner which assures maximum protection to all of the rights of the natural parents and of the child involved." In re A.W., 241 Kan. 810, 814, 740 P.2d 82 (1987). To read termination of parental rights into the permanent guardianship statutes, as does the dissent, would result in severance of parental rights without these necessary and important protections, and without any clear indication that the legislature intended such a drastic effect.

[23] Our own Supreme Court has recognized a parent’s fundamental liberty interest in the relationship with his or her children: "We agree that the termination of parental rights is an extremely serious matter and may only be accomplished in a manner which assures maximum protection to all of the rights of the natural parents and of the child involved." In re A.W., 241 Kan. 810, 814, 740 P.2d 82 (1987); see In re B.D.-Y., 286 Kan. at 697-98, 187 P.3d 594. And another panel of our court recognized that "the private rights affected by governmental action are very significant and are entitled to the highest protection from unwarranted governmental action."

“Statutes pertaining to adoption, relinquishment, or termination of parental rights are strictly construed as they all affect a parent's liberty interest in the custody and control of his or her children.” In re J.A.C., 22 Kan.App.2d 96, 100–01, 911 P.2d 825 (1996) (citing In re A.W., 241 Kan. 810, 814–15, 740 P.2d 82 1987 ). Whether K.S.A. 2014 Supp. 38–2273(a) should be modified to allow the State to appeal the denial of a motion to terminate is a question for the legislature, not this court.

Indeed, our Supreme Court has stated in dicta that there is “no merit in the contention that judicial proceedings, per se, subject a parent to duress which might invalidate a voluntary relinquishment.” In re A.W., 241 Kan. 810, 816, 740 P.2d 82 (1987). Mother also refers to her general “psychological status” to argue that she involuntarily relinquished her rights to the children.

Taken together, K.S.A.2013 Supp. 38–2268 and the form authorized by K.S.A. 59–2143 require that the relinquishment of parental rights be knowing, free, and voluntary. In re C.P., 2014 WL 349616, at *5; see also In re A.W., 241 Kan. 810, 816, 740 P.2d 82 (1987). Even if it were not required by statute, since a parent's right is fundamental and constitutionally protected, due process would require that the relinquishment of parental rights be voluntary.