Huh? That API requires a file handle. Which you get by opening a file. Which you can't do because you can't find it on the filesystem when it's not there.
You're suggesting opening every single FD of every single process (which might not even point to a file, let alone a file on that volume) and querying it just to do this? I mean, sure, I guess that's usually not physically impossible (unless e.g. /proc is unavailable/unmounted)... but it's clearly a hack.
In fact, I think it's not just a (slow!) hack, but a buggy one too. Every time you open a an object that doesn't belong to you, you extend its lifetime. I think that can break stuff. Like imagine you open a socket in some server, then the server closes it. Then that server (or another one) starts up again and tries to bind to the same port. But you're still holding it open, so now it can't do that, and it errors out.
No I'm just saying it's possible. I can count on the fingers of 0 hands the number of times I've needed to do this to edit a deleted file out from under a process that has the only reference to an unlinked file open so at least in my experience it's merely acadamic knowledge!