I had this problem on 9.10 update to from Linux version 2.6.31-14-generic to 
Linux version 2.6.31-20-generic
After kernel update I got the must load kernel first message. 
It apperas that grub cannot load kernels if they are located beyond the 1st 
4Gig of drive space. 

I found a patch to  WUBI file (wubildr file). If was on source forge and had a 
link to update the file
http://sourceforge.net/apps/mediawiki/bootinfoscript/index.php?title=Boot_Problems:Wubi_9.10

I was already booted into an old kernel that still worked (.14)and I didnt want 
to wait for windows 7 to slow boot just to replace one file so i just renamed 
the old wubildr file and copied the new downloaded on into its place from 
ubuntu 2.6.31-14. (from Linux file is located in  /host directory)
After replacing this file reboot and choose latest kernel. I am writing this 
note from kernel 2.6.31-20. WOO HOO!!!

Mark

-- 
"you need to load the kernel first"
https://bugs.launchpad.net/bugs/387326
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