I have seen the occasional firmware update that required a minimum firmware revision before applying, so if you were lower than that you had to upgrade to the minimum required first. But this was because that minimum revision introduced some major data structure change, and the later firmware update had dropped support for migrating data/settings from the older revisions. So always best to review installation instructions as anything like this will ALWAYS be documented.
However, I've only ever seen this type of issue on computer firmware, but then again, I've only ever upgraded the firmware on 2 cameras, and cameras don't seem to have anywhere as many firmware updates as the computers I've used over the years.