Windows users who have Apple's Software Update installed are getting notices that there is a new version of Safari available for upgrade - even if they never installed Safari in the first place. Safari 3.1 for Windows is Apple's first Safari version not to carry the Beta monikor.
There are definitely two schools of thought on this one.
The first is that Apple is using its market leading position in music jukebox software to push its browser - like Microsoft used its market leading position in operating systems to push IE a few years back. While effective, it isn't really fair to the Firefoxes and Operas of the world who don't have that leverage to fall back on. It is also a bit misleading to say it is a "software update" when it was never installed in the first place.
The other school of thought is that Apple isn't forcing this on anyone. There is simply a Apple (not iTunes) software update that is letting Windows users know that there is