According to the POSIX spec, it should be interpreted as 1:
"the current line is set to the last inserted line or, if there was
none, to the addressed line.
[..]
Address 0 shall be valid for this command; it shall be interpreted
as if address 1 were specified."
[..]
However, I think the spirit of the text does suggest that the current
address should be 1. :)
That said, the descriptions for Change and Delete explicitly state "the current
line number shall be set to zero" in some situations, so perhaps if an explicit
address of 0 is given as input, it should be "interpreted as 1" for the purpose
of Insert, but kept at 0 if no input was provided.