Interesting to note that kbd/src/deallocvt.c contains this:

} else if (num == 1) {
        fprintf(stderr,
                _("%s: VT 1 is the console and cannot be deallocated\n"),
                progname);
        exit(1);
}

This is decided in userspace without asking the kernel, suggesting that
someone, somewhere believed tty1 really is a special case.

-- 
Headless on beagle, beagle XM, does not boot into tty
https://bugs.launchpad.net/bugs/652221
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