For me the issue here is needing the Apple TV, and some of it's apps, to support changing the output frame rate based on the content playing.
As has been noted in this thread, depending on where the content originates from it can be 24p, 25p, 30p, 50i or 60i (so far...) and at present the ATV has a fixed output depending on what you select in settings. Auto simply negotiates 1080p/60 as it thinks that's the best as it's the highest frame rate.
60Hz is rubbish for any (mainly European) 25p/50i content including apps like BBC iPlayer, but is best for 24p, and largely US sourced material. Many TV's can now correctly display 24p from a 60Hz playback, but what's best for 60Hz is rubbish for 50Hz and vice versa.
In the US this isn't a problem generally as many US TV's don't support 50Hz at all, so I imagine either the BBC for example generate 60Hz friendly content for the US shows they export, or people in the US are used to lots of judder for European content.
However in Europe all HD TV's support 50Hz and 60Hz modes, and using the right one makes a huge difference to content quality.
So really, ATV needs a mode that apps can use that allows them to change the output frequency based on the content, and perhaps a setup wizard where users can select all the modes their TV supports, so that you can disable 50Hz for example in the US where support is lacking.
That would make TV apps on ATV far more friendly for content viewing. OK, there would be a bit of screen flicker when the TV changes modes, but I'd much prefer that to constant judder and then having to manually mess around in setup depending on content type which you're not always aware of.