Assume you have three view controllers instantiated like so:

UIViewController* vc1 = [[UIViewController alloc] init];
UIViewController* vc2 = [[UIViewController alloc] init];
UIViewController* vc3 = [[UIViewController alloc] init];

You have added them to a tab bar like this:

UITabBarController* tabBarController = [[UITabBarController alloc] init];
[tabBarController setViewControllers:[NSArray arrayWithObjects:vc1, vc2, vc3, nil]];

Now you are trying to do something like this:

[tabBarController presentModalViewController:vc3];

This will give you an error because that Tab Bar Controller has a death grip on the view controller that you gave it. You can either not add it to the array of view controllers on the tab bar, or you can not present it modally.

Apple expects you to treat their UI elements in a certain way. This is probably buried in the Human Interface Guidelines somewhere as a "don't do this because we aren't expecting you to ever want to do this".