You might get this error while working on zend form which has select element on it. And most probably you are messing with this element on your controller or from your front end friend javascript [ that was in my case ]
Just put the following in the controller and you should be fine
$form->getElement('selectElementNameHere')->setRegisterInArrayValidator(FALSE);
This is a behavior of zend adding a default validator of inarray.
You would find more detailed explanation on zend website.
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