This article in The Guardian suggests a story where the butler did it earlier than that - The Strange Case of Mr Challoner in 1921.
Even so "the butler did it" is still a great example of a cliché that hardly ever actually happens.
I could easily believe the cliché originated independently from any particular book, purely as a piece of writing advice meaning "don't be obvious!"


The most famous is "the butler did it," which is a cliche with that apparently predates the reference.
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