Trying to find a Jeep without mud is like trying to find a sailboat that has not seen water, unless of course you live in a desert.
For a 12 year old Jeep, it looks pretty clean but that's only one picture. I'd ask for the maintenance reports, CarFax report, check the oil and trans fluids for metal particles and milk shakes. Also Check the anti-freeze to make sure it looks clean (again no milkshakes present).
Look for undercarriage damage to the belly pan, gas tank skid plate and differentials.