Deleted file recovery from a live volume is like Russian roulette. Clusters that were allocated to the file may be overwritten at any time.
If we then add SDD and SMR drives to the equation those clusters may be 'trimmed' virtually immediately. It depends on the SSD if it then returns zeros when we try to access those clusters using file recovery / undelete software or gibberish. And again if those clusters are used for new newly written data you may get gibberish too. If some compressed data for example is written to the clusters and you try reading that as Word document or text, it will appear to be gibberish. So in case of SSD we have two mechanisms at work that work against you.
Reason undelete software can detect these files is that the file system data itself is not trimmed. For example in NTFS it's mostly a matter of flipping a flag in MFT entry for the file (used: y/n). Apart from that logs may be updated as well as the $Bitmap file which tracks used/unused clusters.
Info on TRIM: https://en.wikipedia.org/wiki/Trim_(computing)
Video with some examples: https://youtu.be/hzClnwGeJUM