The Carry On moment involving the Scots-born politician was revealed by Angela Eagle, the Shadow Commons Leader, during Business question time.
She told MPs: "He hasn't had the most auspicious of starts. Yesterday, he not only lost his first vote but he managed to get stuck in the toilet in the wrong lobby and he nearly broke his own whip."
William Hague, another reshuffled minister, who has been demoted as Foreign Secretary and is the new Commons leader, defended the honour of his Edinburgh-born colleague, saying: "Knowledge of who is in the toilets in whatever lobby is a very important piece of information for any Chief Whip."
On Tuesday, Mr Gove was removed as Education Secretary, a move that cost him nearly £36,000-a-year in salary.