BOTH file system types get checked on bad shutdowns, and it has NOTHING to do with the file system. It has EVERYTHING to do with Windows' OS procedurals.
Journaling file systems DO check themselves independently of the OS they run under. The support for them by the OS means that such routines are built in. A bad shutdown makes a call to the checking routine upon restart.
It is hard to design a file system that can handle being shutdown while a write operation is taking place safely.
The system you describe would be easy. Simply set a flag on the drive after any and all successful writes. Remove the flag during any write op, and set it after.
If the flag is there on startup, the file system is considered whole and valid.
It still has a safety concern, but very little. Older drives could "spray" "bits" all over the drive's recording area as the head retracted during a shutdown mid-write. Drive electronics on the drive itself has since solved this problem. The exception would be a power surge passing the whole way through, but such an animal would likely trounce the drive electronics well before it hit the platters.