This fails in the GUI in cases such as if you accidentally hit navigation keys close to the Del key, like Home, End, etc. In those cases you may accidentally change the file selection in the same movement as the deletion, and then you whack the wrong file.
If you’re the person in charge of making the delete operation the best and safest it can be, you do not have the luxury of yelling at users to just be more careful, because the data shows very plainly that doesn’t work (despite this being the approach most IT people seem to think is acceptable). In this role, with these constraints, the inevitable conclusion is the make a trash can.