BRL, not really. Once you've done the second stage of delete, ie emptied the Recycle Bin, you've got the use of the space already. Also when you do Shift/Del; the disk space is made available immediately.
Same principle as on a 3½" floppy; delete all files on a floppy and the space is there straight away. But until the data is over-written by new data it can be recovered by suitable, and cheap, programs. File deletion merely erases the first character of the filename in the Table of Contents (TOC). The undelete program finds these truncated filenames and invites you to input a character to rebuild the name. But if the data itself has been over-written, you will be told that the file is unrecoverable.
I've found this useful a few times for folks who've kept a year's work on a single floppy and never even backed it up!
Much, much cleverer are the procedures the Constabulary use when they can recover data that you thought you had over-written to disguise why you've got that Ferrari parked in the driveway. They can read track spillage in some way.