Also ran into this with FAT32 boot partition, during in place upgrade
from 8.04 to 8.10.  Seems like hard linking is a requirement for package
installation so I'm using an unsupported configuration.  Just commenting
for completeness.

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memtest86+ 1.60-1 fails to install with FAT16 /boot
https://bugs.launchpad.net/bugs/22534
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