Litter in the garden? (3)
I believe the answer is:
bed
This clue is a double definition.
'litter' is the first definition.
(thesaurus)
'the garden?' is the second definition.
(I've seen this in other clues)
'in' acts as a link.
(Other definitions for bed that I've seen before include "(Garden) plot" , "Bottom < layer" , "Bottom of the sea or river" , "Place for patient in hospital" , "Matrimonial duties" .)