So the failure mode I ran into was running the upgrade to 19.10 after
upgrading all disco packages but before rebooting.

In that case it seems like the upgrader needs to refuse to run if the
system needs to be restarted?

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https://bugs.launchpad.net/bugs/1844805

Title:
  virtualbox, virtualbox-dkms, virtualbox-qt fail during upgrade from
  19.04 to 19.10

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