There is no obligation on the part of the developer to deliver _any_ upgrade.
A paid upgrade would be a clear signal to users of the free version that there will not be any free upgrades in the future. Some users would prefer knowing that over the uncertainty of 'will this app ever be updated?/will that one bug ever be fixed?' that they get when an app does not see updates for months/years.
A paid upgrade would be a clear signal to users of the free version that there will not be any free upgrades in the future. Some users would prefer knowing that over the uncertainty of 'will this app ever be updated?/will that one bug ever be fixed?' that they get when an app does not see updates for months/years.