Fiqh of Hadith: Nafelah and Qiblah by Sh. Kifah Mustapha
Jaber, the son of Abdullah, said, “The prophet (pbuh) used to pray on his (camel) which ever way it turned (in direction), but when it was time for the obligated (Salah) he would step down and face Qiblah.” Hadith narrated by Bukhari. (كان رسول الله صلى الله عليه وسلم يصلي على راحلته حيث توجهت فإذا أراد الفريضة نزل فاستقبل القبلة).
 In this Hadith, a clear reference to pray (Nafelah), the non-obligated Salah, while riding is permissible regardless of which direction. Imam Nawawi said, “This is permissible by consensus of Muslims.” It is also not a condition to begin the non-obligated Salah facing the Qiblah.Scholars say that the road itself would become the direction of the traveler while praying. With that in mind, scholars said that it is not permissible to keep moving your head in different directions while praying.
This Hadith did not specify how the performance of Salah itself is conducted, but in another Hadith narrated through Amer, son of Rabee’ah, he said, “I saw the prophet (pbuh) on his camel praying (nafelah) non-obligated Salah nodding his head toward any direction.” This narration speaks of one type of movement of the head (representing the changing positions of prayer), but scholars say that the head would be lower during Sujood than during Ruku.’
However, people traveling in planes are even allowed to pray the obligated Salah toward the direction of the plane because of safety and necessity.
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