Public bug reported:

Disabling/locking a user account will not prevent a user from logging into your 
server remotely if they have previously set up public key authentication.

A workaround is to restrict access to a sshlogin group and parallely 
maintaining it,
https://help.ubuntu.com/9.10/serverguide/C/user-management.html
however sshd should always check if user has not been locked (PAM).

** Affects: openssh (Ubuntu)
     Importance: Undecided
         Status: New

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public key authentication grants access even for locked accounts
https://bugs.launchpad.net/bugs/496008
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