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As with extending volumes, several limitations apply to shrinking volumes. First, you can shrink simple and spanned volumes only if they are formatted and the file system is NTFS. You can’t shrink striped volumes. You can’t shrink volumes that are formatted with FAT, FAT32, exFAT, or ReFS. However, you can shrink volumes that have not been formatted. If a volume is heavily fragmented, you might have to defragment the volume to free up additional space before shrinking.

From

Cover of Windows Server 2012 R2 Inside Out: Configuration, Storage, & Essentials

Note

Shrink volumes limitations.