There are (at least) three scenarios where this can happen:
(1) During the switchover from RPT (Rendez-Vous Point Tree) to SPT (Shortest Path Tree), there may be packets transiently received through the RPT that gets discarded for RPF-failure due to the fact that the local router already converged to the SPT.
(2) Unicast routing instability e.g. a BGP session flaps. This leads to transient drops for RPF-failure.
(3) In a multiaccess network like a LAN you can have R1, R2, R3. R1 sends a join to R2, and that brings the traffic to R3, even if R3 is not interested. And R3 may have a better route to the source via a different link. This is drop due to permanent RPF-failure condition.