Win9x requires too much direct access to hardware.
Keep in mind that NTVDM itself runs a customized Windows 3.1 for 16-bit compatibility.
I've run Windows 1 and 2 in 9x DOS boxes before.
But with Windows 3.1 you would have to massively scale back what it tried to access (no mouse, no direct file system access). I don't recall what the specific limiting factor(s) are, but I don't recall that it would work.
Comments
Keep in mind that NTVDM itself runs a customized Windows 3.1 for 16-bit compatibility.
I've run Windows 1 and 2 in 9x DOS boxes before.
But with Windows 3.1 you would have to massively scale back what it tried to access (no mouse, no direct file system access). I don't recall what the specific limiting factor(s) are, but I don't recall that it would work.
But knock yourself out if you want to try.