That's really anything to do with the file system anyway. Recycle Bin isn't a feature of NTFS/FAT, it's a feature of Windows, and there's plenty of things available in Linux that do the same thing for EXT3/4 and I assume work fine for any natively supported FS. It's not like it's magically "undeleting" files, it just moves them to some other location, which the OS may choose to handle differently to normal directories.
Even after you remove it from there, the data's still on the disk, until that part of the disk gets written over. I guess you could have some sort of filesystem level backup of deleted files, but it's still just a lower level abstraction of "moving the file somewhere you can't see it" rather than "removing" it.
In the end, if you're deleting files because you're need the disk space for something else, you're probably going to want to write over those bits at some point. I can't see much benefit of a filesystem level version of 'undelete' besides working across OSs, and that'd actually require the OSs to support it. I guess it'd be a 'catch all' for different desktop environments/UIs/command lines.