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There is a curry that is hotter than a Phal that is available at any Indian restaurant.Simply tell the waiter to tell the chef that he is a wimp with his spiciness and even your wife could eat his 'so-called' Phal. See what turns up on your plate as a result. Also, keep an eye on the window to the kitchen as most of the staff will want a laugh as you attempt to eat their death curry. Unfortunately, in order to save face, you will have to eat the whole thing without sweating or swearing. If you win the battle you will become a legend!
Possibly, in a restaurant, but at home there are no limits : a Phal is just a name, you can create a dish as hot as you wish !Incidentally, I too used to love Phals, until one day I developed IBS. I then had to lay off curries completely for several months (almost as bad as giving up sex), and then re-start with Bhunas. Now I normally eat Madras, and will go as far as a Vindaloo ('though in general I regard these as a waste of money : you are paying for potato when you could be paying for chicken !), but I will never again intentionally eat a Phal.** Phil.