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I just did a module update of 2.14 in XOOPS 2.3.3b site and it completed just fine.
What version are you upgrading from? My notes say that if you are updating from before 2.1RC2, then you must update to that module first before going to 2.14 (or 2.13).
You might also check all your file permissions. Let me know, I use SmartSection regularly.