This is actually a bug in package ucf, identical to Debian bug 574266
(https://bugs.debian.org/cgi-bin/bugreport.cgi?bug=574266#18), which was
recently fixed with a one-line patch.

The code that tested for terminal availability would fail if the debconf
ncurses interface (whiptail) was used, and the program was /not/ run
under X.  So when upgrading from the console or via ssh (without the -x
option), it would always generate this error message,

For additional details, see the Debian bug report, which includes a
patch.


** Bug watch added: Debian Bug tracker #574266
   http://bugs.debian.org/cgi-bin/bugreport.cgi?bug=574266

** Package changed: update-manager (Ubuntu) => ucf (Ubuntu)

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https://bugs.launchpad.net/bugs/768614

Title:
  No terminal, and no DISPLAY set, can't fork shell.

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