He was sleeping in the same bed (where) his girlfriend had died last year.
Both versions sound okay to me. Is "where" necessary or unnecessary? Why?
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Where is considered appropriate here, just informal. "Where" might just seem strange to me because it's a bed and not a building or something, but I think it's fine.
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Original answer below:
I don't think "where" is the proper word here. To me, "in which" sounds much more appropriate, as in
He was sleeping in the same bed in which his girlfriend had died last year.
I can't tell you exactly why, but I would use "where" if there isn't an object.
He was sleeping where his girlfriend had died.
Alternatively, you could write it as
He was sleeping in the same bed his girlfriend had died in last year.
He was sleeping in the same bed that his girlfriend had died in last year.
To clarify about why "where" seems wrong to me:
If I say, "He is sleeping there", you might ask, "Where?" So, you can write
He is sleeping where she had died.
If I say, "He is sleeping in this bed", the question isn't, "where?", the question is, "which bed?" So, you can write,
He is sleeping in the bed which she had died in.