Windows dosent have the concept of an inode, so there is nothing for a file handle (what windows calls a file descriptor) to bind to except a file name, this means that a filename cannot be removed while it is being accessed somehow.

This is the cause of a lot of woes on windows, such as random access denied errors when attempting to delete stuff, and what forces a reboot when you update nearly anything on windows.

One of my favourite things related to this is that the Windows XP explorer had a bug where clicking on a file would generate a dynamic preview of an audio/video file in the sidebar, which would lock the file, rendering it impossible to delete because you had to click on it first....