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The earliest I could locate was a Mexican film El Tren fantasma as described here.

The General (1926) starring Buster Keaton was known for its action in a train, but I am unable to reliably establish if there was a fight on top of a moving train.

Is there any older movie which has such a fight?

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You can download a free version of The General at – knut Sep 23 '12 at 19:57
up vote 13 down vote accepted

The oldest I know is "The Great Train Robbery" (1903).

There is a youtube clip, see scene 4, approx. in minute 4ff

There are more information about the film at:

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And the first narrative film: – Hugo Sep 26 '12 at 10:08

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