The job itself looks OK, although I have a few related questions:
Shouldn't you be using dh_installinit to install the job and deal with migrating the old conffile? Simply dropping the new job in place and removing the call to dh_installinit is generally not the correct thing to do.
The old init script has a few specialised warts that you don't seem to have preserved. Obviously a lot of it goes away with Upstart, but I think the inetd.conf check (even though it's clunky) is probably worth preserving. What about the ntp-wait gubbins? I can't think of an easy way to do "start on started ntpd but only if it's installed" in Upstart, so you may have to preserve that too for the moment.
The job itself looks OK, although I have a few related questions:
Shouldn't you be using dh_installinit to install the job and deal with migrating the old conffile? Simply dropping the new job in place and removing the call to dh_installinit is generally not the correct thing to do.
The old init script has a few specialised warts that you don't seem to have preserved. Obviously a lot of it goes away with Upstart, but I think the inetd.conf check (even though it's clunky) is probably worth preserving. What about the ntp-wait gubbins? I can't think of an easy way to do "start on started ntpd but only if it's installed" in Upstart, so you may have to preserve that too for the moment.