Until about 1977, the Meijin event was conducted with a 5 point komi, with White to win in case of a tie ('jigo'). In a match, this is effectively the same as 5.5 komi, but in this league, a White win by a tie (W+jigo) was not worth the same as any other win. Thus Shuko won the 1st Meijin league (1962) ahead of Go Seigen because Go's win against Sakata was a jigo win with White, while all of Shuko's wins were fully valued. (Shuko also happened to win his individual game against Go Seigen, but that seems to have had no extra value.)
Source - The Go Players Almanac, Bozulich (Ishi Press, 1992).