It should be EAGAIN, per POSIX 1003.1-1996 section 3.1.1.4:
3.1.1.4 Errors
If any of the following conditions occur, the fork() shall return -1
and set errno to the corresponding value:
[EAGAIN] The system lacked the necessary resources to create
another process, or the system-imposed limit on the
total number of processes under execution by a single
user would be exceeded.
For each of the following conditions, if the condition is detected,
the fork() shall return -1 and set errno to the corresponding value:
[ENOMEM] The process requires more space than the system is
able to supply.
-hpa
--
"Linux is a very complete and sophisticated operating system. There
are, and will be, large numbers of applications available for it."
-- Paul Maritz, Group Vice President for Platforms And Applications,
Microsoft Corporation [Reference at: http://www.kernel.org/~hpa/ms.html]
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