If the IBM Notes client and the IBM Domino server are installed on the same MS Windows server/workstation, then the JVM installer that has both code for the client and the server always installs the JVM update to the client, and doesn't apply the patch to the server.
This solution is from a post that is from a post which Ulrich posted a solution.
D:\temp\> 22.214.171.124_Server_w32_JVM_Patch_20150724_12345678.exe LAX_VM d:\ibm\domino\jvm\bin\java.exe -D$USER_INSTALL_DIR$=d:\ibm\domino
Update the name of the JVM patch to the current filename.
Update both of the d:\ibm\domino paths to your install.
To view the new JVM version, in Domino console, enter:
> sh jvm
If there is an error, the Patch Update program should display a message to check: