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Try to clone git://github.com/bokowski/empty.git and try to add a branch using org.eclipse.jgit.api.CreateBranchCommand. I get org.eclipse.jgit.api.errors.RefNotFoundException: Ref HEAD can not be resolved.
I haven't checked it, but I assume the repo doesn't contain any commits (no HEAD), so the current behavior is actually expected. Chris, could you confirm and close the bug if I'm right?