How would you expect recode to know that a file is Windows-1252? In theory, I believe any file is a valid Windows-1252 file, as it maps every possible byte to a character.
Now there are certainly characteristics which would strongly suggest that it's UTF-8 - if it starts with the UTF-8 BOM, for example - but they wouldn't be definitive.
One option would be to detect whether it's actually a completely valid UTF-8 file first, I suppose... again, that would only be suggestive.
I'm not familiar with the recode tool itself, but you might want to see whether it's capable of recoding a file from and to the same encoding - if you do this with an invalid file (i.e. one which contains invalid UTF-8 byte sequences) it may well convert the invalid sequences into question marks or something similar. At that point you could detect that a file is valid UTF-8 by recoding it to UTF-8 and seeing whether the input and output are identical.
Alternatively, do this programmatically rather than using the recode utility - it would be quite straightforward in C#, for example.
Just to reiterate though: all of this is heuristic. If you really don't know the encoding of a file, nothing is going to tell you it with 100% accuracy.
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