There's no voltage drop unless there is current flowing. If he took that measurement while the starter circuit was NOT engaged, it's battery voltage. (But if you're testing batteries, why not just test the batteries?)
That's why a test light should be used as well as a meter. The meter won't load the circuit, so you don't see a voltage drop due to a bad connection, corroded wires, etc. A test light usually provides enough load to show the drop. I doubt it would on a starter circuit, though.