I heard this, and of course I totally and utterly disagreed with it at the time, because I thought it was 0 too.
The following ripped from Steven Lynch's column, correct as at March 2004....
(the original question was about the lowest individual total which had never been made, but I left the reply to that in for authenticity:
The last time I was asked that question the answer was 228 – but that's now been done, by Herschelle Gibbs for South Africa v West Indies at Cape Town in January 2003. So the lowest score never made in a Test is now … 229. For the record, the only other scores under 250 which have never been recorded in a Test are 238, 245, 248 and 249. The most-common score in Tests is, not surprisingly, 0 (7368 instances, including not-outs), followed by 1 (2963). Perhaps slightly oddly, more batsmen have made 4 (2390) than 2 (2323).
So it WAS 0 after all.