I don't see any feature of sshd that provides for limiting the number
of sessions.  I suspect it wouldn't be all that difficult to add such a feature.
There is a feature to limit the number of sessions that have not yet
completed the authentication phase, but I don't know how much that would
help you.

But I don't recall that you said _why_ you wanted to limit the number of
sessions, which may matter because there may be other ways of achieving
certain results.  For instance, setting up IPQoS might control the maximum
bandwidth that incoming ssh connections (and the return traffic) could use
(but don't _think_ about asking me how to set that up; just looking at it
gives me a headache).  Or there might be some way to use resource
controls to limit CPU usage by sshd (maybe...I haven't thought that one
through).  Anyway, the real question remains what are you actually trying
to accomplish, and is there any other way of doing it?
 
 
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