That limit is 10+ year old and the other major search engines do the same. Users do paginate, but those going to page 99 are more than likely automated systems. A user who hasn't found a good result by page 50 should change their search query with + and - terms.
I imagine with something like Google Scholar it might be more of an issue. I'm much more likely to go very deep into the results there.<p>I wonder how often that's an issue for users. With the amount of testing and research google does on user experience it's probably vanishingly small. But I wonder if, when it's a problem for a user, is it a really big problem?