Some mycobacterium have not met the postulates probably because it's a small intracellular bacteria. Mycobacterium is so small and acts similar to a virus, so they used to think it was a virus.
"Uncultivable bacteria in the history of microbiology are not new. Mycobacterium leprae and Treponema pallidum, two of the oldest pathogens of man are still uncultivable in artificial media. In recent years Bartonella henselae, the causative agent of bacillary angiomatosis[2] and cat-scratch disease, and Tropheryma whippelii the causative agent of Whipple's disease[3] have emerged as newer uncultivable pathogens."