> I haven't been able to find where in upstart this is happening, but on the 
> kernel side I can tell that it's due to an open() without
> O_NOCTTY. 

Upstart does not open /dev/console without O_NOCTTY afaics. Are you sure
your kernel debug is showing pid 1 is doing this?

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https://bugs.launchpad.net/bugs/1263738

Title:
  login console 0 in user namespace container is not configured right

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