Edit: since there still seems to be confusion I'll try to be clearer. On NTFS you can delete an open file. This is a solved problem. The DeleteFile API even does this by default now. The thing that prevents deletion is an OS lock. This lock only prevents deletion. Renames are still allowed.
In that case, the file exists only for the process which has already opened it.
That's not exactly rocket science. Anyone can do that, there's tools for that.
The High-Performance File System, a.k.a. HPFS, has been included in OS/2 1.2, which was launched in November 1989.
HPFS was a very innovative file system (its chief architect was Gordon Letwin). It has introduced the Extended File Attributes. It had directories implemented with B+ trees, like IBM VSAM (introduced at some time between 1973 and 1978). It had long file names and Access-Control Lists, like the Multics FS (1965). It used cylinder groups like the Berkeley FFS (1983). It used file extents, like the SGI EFS (1988).
Among the UNIX file systems, the SGI XFS (1993, almost simultaneous with NTFS) has been the first which has added all the innovations introduced by HPFS.