Dominik said:
target_freq cannot be below policy->min or above policy->max.
If it were, the whole cpufreq subsystem is broken.

But (answer):
I think the "ondemand" governor can ask for a target frequency that is
below policy->min.
...
A patch such as below may be needed to sanitize the target frequency
requested by "ondemand". The "conservative" governor already has this check:
Signed-off-by: Thomas Renninger <trenn@suse.de>
Signed-off-by: Dave Jones <davej@redhat.com>

# diff -bur x/drivers/cpufreq/cpufreq_ondemand.c.orig y/drivers/cpufreq/cpufreq_ondemand.c