Ubuntu Figuring Out Whether To FSCK Its File-Systems At Boot
This bug report from 2018 points out that Ubuntu Server is setting "fs_passno" to 0 which means no FSCK at boot. This is a regression and change in behavior from prior Ubuntu Server installs to Ubuntu 18.04 and beyond where they introduced their new Curtin-based Subiquity installer where FSCK is not happening. That bug wasn't touched since early 2019 but is now being re-visited by Ubuntu developers.
There is also this bug from 2017 pointing out "fs_passno" is being set to 0 by defult leading to no FSCK at boot.
Those bugs are now picked up by Ubuntu developers and being figured out whether they want to enable FSCK at boot with Curtin moving forward, especially with Ubuntu's new desktop installer to make use of Curtin as well.
Michael Hudson Doyle of Canonical started the discussion now of To fsck or not to fsck at boot by default. He acknowledges some modern file-systems like XFS / Btrfs / OpenZFS do not support any meaningful FSCK but for cases like EXT4 and the EFI boot partition it may make sense enabling the functionality.
So it's likely Ubuntu Server and other Curtin-based Ubuntu installations will see FSCK at boot enabled by default for file-systems where relevant but for now he left it up to the community Discourse for collecting feedback.