Remember that quality of job and watertightness is all important, even with shower enclosures upstairs.
I have had leaks from upstairs shower trays down into the rooms beneath, doesn't need to be a fancy wet room for leaks to occur!!
If the house is new, settling can cause small leaks even in tiled showers. My leak came from a shower enclosure that was tiled half on a solid wall, and half on a stud wall. The house was new, settled over time and there was very minimal movement in the tiling/enclosure etc, but enough to let water downstairs.