It may always work from the kernel's standpoint, but this doesn't necessarily make it usable.
Anything that blocks the display of WinLogon (e.g., the GPU has crashed and is unresponsive) would render this emergency restart mechanism unusable, and typically, situations like this are usually the only time I would need such a feature.
Windows since 8 has worked on hardening/strengthening the "Secure Desktop" that login flows (and UAC prompts) happen on so that as much as possible malware shouldn't be able to run in those sandboxes.
[0] https://docs.microsoft.com/en-us/windows/security/threat-pro...
Happy to be corrected by someone who knows more about the windows kernel. :)