Yes, because it doesn’t do as much to protect you from data corruption.
If you have a use case where a barely-measurable increase in speed is essential, but not so essential that you wouldn’t just pay for more RAM to keep it in cache, and also it doesn’t matter if you get the wrong answer because you’ve not noticed the disk is failing, and you can afford to lose everything in the case of a power cut, then sure, use a legacy filesystem. Otherwise, use a modern one.
When I was still dual-booting Windows and Linux, I found that “raw disk” mode virtual machines worked wonders. I used VirtualBox, so you’d want a guide somewhat like this: https://superuser.com/questions/495025/use-physical-harddisk-in-virtual-box - other VM solutions are available, which don’t require you to accept an agreement with Oracle.
Essentially, rather than setting aside a file on disk as your VM’s disk, you can set aside a whole existing disk. That can be a disk that already has Windows installed on it, it doesn’t erase what you have. Then you can start Windows in a VM and let it do its updates - since it can’t see the bootloader from within the VM, it can’t fuck it up. You can run any software that doesn’t have particularly high graphics requirement, too.
I was also able to just “restart in Windows” if I wanted full performance for a game or something like that, but since Linux has gotten very good indeed at running games, that became less and less necessary until one day I just erased my Windows partition to recover the space.