>> 1. ~ $ emacs -Q
>> 2. Menu -> Options -> Show/Hide -> Tab Bar (gives Tab*scratch*)
>> 3. resize the Emacs window to a small one, but large enough to show some Tab labels
>> 3. 1x click on rightmost * in the Tab Bar to create a new Tab
>>
>> The bug: No new Tab will be created and the minibuf and*Messages*  show:
>>
>>    split-window: Window #<window 3 on*Messages*> too small for splitting
>
> Thanks for the bug report.  It is related to bug#62427 where
> we need to find a way to create a new window without using
> delete-windows and split-window.

Oh, I noticed the same problem in window-state-put too :-(
Restoring window states fails with the same error in narrow windows.
However, here is a fix.  Eli, is it ok to fix this in emacs-29?