Whatever the definition and no matter the spicing, whether freshly ground, freshly compounded or even (except when aged, and like chewing gum, having lost its flavor on the bedpost overnight) made with "curry powder", in my travels (and at home) I've rarely met a "Curry" I didn't like (although frog legs just don't work for me).

Hottest curry? Back about 1963, some stand-up joint on the "Gut" in Valetta, Malta,
dark red, goat or mutton (elderly), and about double the strength of raw jalapeno with seeds and internal fiber. The "Gut" was so disreputable that you needed a hot curry to protect you from diseases so contagious as to not even require direct contact.