Public bug reported:

Binary package hint: update-manager

Running do-release-upgrade on latest 9.04 / Jaunty within a Linux-Vserver Guest 
yields:
(see attachment for full log)

$ do-release-upgrade -m server -d
...
Preparing to replace upstart 0.3.9-8 (using .../upstart_0.6.3-10_amd64.deb) ...
Unpacking replacement upstart ...
Setting up upstart (0.6.3-10) ...
telinit: No such process
dpkg: error processing upstart (--configure):
 subprocess installed post-installation script returned error exit status 1
Errors were encountered while processing:
 upstart
Exception during pm.DoInstall():  E:Sub-process /usr/bin/dpkg returned an error 
code (1)

Could not install the upgrades

The upgrade is now aborted. Your system could be in an unusable 
state. A recovery will run now (dpkg --configure -a). 

Please report this bug against the 'update-manager' package and 
include the files in /var/log/dist-upgrade/ in the bug report. 
installArchives() failed 

Setting up upstart (0.6.3-10) ...
telinit: No such process
dpkg: error processing upstart (--configure):
 subprocess installed post-installation script returned error exit status 1
Errors were encountered while processing:
 upstart

Upgrade complete

The upgrade is completed but there were errors during the upgrade 
process.

** Affects: update-manager (Ubuntu)
     Importance: Undecided
         Status: New

-- 
Setting up upstart within linux-vserver fails if telinit is not running
https://bugs.launchpad.net/bugs/454783
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