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Re:Introducing ART – A new Android runtime being introduced ... by djh_ on Friday November 01, 2013 @07:52PM (#6657376)
Google made changes to how the JNI returns references to Java objects in Ice Cream Sandwich (4.0) so that native code can work with a moving GC.

http://android-developers.blogspot.com/2011/11/jni-local-ref...

Doesn't answer your question, just some supporting evidence.

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