Probably wouldn't happen though, I think the game developers want us to feel a little frustrated at the game, to keep us addicted. Also, it wouldn't really qualify as a HM, unless perhaps... ok, imagine this:
You're in the early stages of the game, and there are several routes around you. The easiest route is blocked off, but the other route contains powerful wild Pokemon at level 65, impossible to catch with your measly regular Pokeballs and impossible to run from either, so any time you attempt to go down the route, your Pokemon just end up feinting. Then you obtain the HM and can pass through this route unharmed. You know what? It could keep you hidden from trainers as well, or help you sneak into places - a psychic invisibility cloak. Hmm... but then you could just skip past everything too easily, maybe....
This would be a nice way for the game to feel a bit more realistic as well. Rather than having a straightforward path from the weak village to the strong cities, there could be several strong cities that you have to go through, without yet being qualified to challenge the gym leaders there (like the dad in gen III). One for the future, maybe.