In fact, there's no known upper limit since the human eye sees a continuous stream of movement, not individual frames. 60 fps was tried in the 70's by Douglas Trumbull with his 70mm film process called Showscan (see the More Coverage link below for its comeback tour), but studios and theaters of the era couldn't stomach the cost of the celluloid it required and the company went bust.
ENGADGET: Editorial: Despite shaky 48 fps Hobbit preview, high frame rates will take off