Massachusetts General Laws Part II. Real and Personal Property and Domestic Relations (Ch. 183-210) Ch. 210, § 11

The supreme judicial court may allow a parent, who, upon a petition for adoption, had no notice of the proceedings before the decree and had neither waived notice in accordance with section two nor been the subject of a decree dispensing with need for notice in accordance with section three, to appeal therefrom within one hundred and twenty days after actual notice thereof.