I’d argue against that. For one thing it is impossible to imagine a situation where there is no change in the gravitational gradient across your body over time. Your orbiting a black hole situation is a perfect example of a situation where the gradient alone would tear you apart. The conditions you’ve specified are tautological. There’s no way to maintain a zero gravitational gradient while also simultaneously having extremely high gravitational field. The two are mutually exclusive in any conceivable scenario.
It’s like saying a human being in a hypersonic wind stream won’t necessarily hurt you, burn you alive and rip you to pieces (not necessarily in that order) as long as there is no turbulence and you have a sufficient boundary layer – but you’re a non-aerodynamic human body in a hypersonic wind stream, so of course there will be turbulence and the boundary layer will not protect you at all, you’re going to die, basically instantly.