>>54817623To be fair, you could softlock yourself with a strength boulder or a cut tree with enough retardation
But if you needed to have the HM in your bag in order to use it then there would be no issue since you'd just be able to teach it back anyway. In gen 1 that wouldn't work because HMs could be deposited into the PC due to gen 1's bag system, that's not the case from gen 2 onwards.
I guess they could prevent you from forgetting it on a mon that can't learn the HM, such as surfing Pikachu, but that's about it.