Here is the regulation:
115-18-8. Retrieval and possession of game animals, sport fish, and migratory game birds; requirements. (a) Each individual wounding or killing a game animal, sport fish, or a migratory game bird shall make a reasonable effort to retrieve the wounded or dead game animal, sport fish, or migratory game bird. The retrieved game animal, sport fish, or migratory game bird shall be retained in the individual's bag, creel, or possession limit, unless prohibited by regulations of the secretary for the individual species taken. Nothing in this subsection shall prohibit the catch and release of live sport fish. (b) Each game animal, sport fish, or migratory game bird retrieved shall be retained until any of the following occurs: (1) The animal, fish, or bird is processed for consumption. (2) The animal, fish, or bird is transported to the individual's residence, to a place of commercial preservation, or to a place of commercial processing. (3) The animal, fish, or bird is given to another person in accordance with K.A.R. 115-3-1 and K.A.R. 115-4- 2. (4) The animal, fish, or bird is consumed. (c) The provisions of this regulation shall not affect any requirement of state or federal law or regulation regarding any proof of species, age, or sex and the attachment of this proof to the carcass. (d) For the purpose of this regulation, “migratory game bird” shall mean any duck, goose, coot, merganser, rail, mourning dove, white-winged dove, snipe, woodcock, or sandhill crane for which a hunting season has been established in this state. (Authorized by K.S.A. 32-807; implementing K.S.A. 32-807 and K.S.A. 32-1002; effective June 8, 1992; amended Jan. 30, 1995; amended Oct. 5, 2001; amended July 25, 2003.)
I take this to mean a bird has to be actually in hand to be counted towards the bag limit.
If you're there for the limit, you're there for the wrong reason