Comment 6 for bug 350491

My suggestion on ubuntu's side for dealing with this problem:

1) Whenever you hibernate, save a copy of the grub menu.lst to a backup location
2) Change menu.lst to boot the currently running kernel by default, with a label simply reading "Resume from Hibernation".
3) If possible, add a warning message to the grub menu that booting any other option will result in a loss of the hibernated state
4) On resume from hibernation, restore the backup menu.lst from step 1.

In this way, no attempt to boot an incorrect kernel will be made until the user explicitly requests it, ie, as part of a manual reboot.