Measurements of the torgue to overcome rigor mortis on the legs of 101 male human cadavers at 5 degrees C are reported. There seems to exist an upper limit, which is dependent on the lay-time, above which no value occurs, but below which every value may be found. By calculating the 90% tolerance limits for lay-times grouped at 12-hourly intervals, this upper limit was found to decrease exponentially with lay-time. This may be used for the estimation of maximum lay-times from rigor mortis measurements.