Aha!
And that flash of inspiration, plus a fresh look, made me realise that
sysvinit only does ioctl(TIOCSCTTY) for the sysinit process - it doesn't
do it for any usual runlevel change ones.
So Upstart is just fine here
** Changed in: upstart
Status: Confirmed => Won't Fix
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compat: sysv-rc not console owner
https://bugs.launchpad.net/bugs/211402
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