From Law wiki, the wiki for law research

[2000] 1 WLR 1962. Confirms Warlow v harrison (1858) that an auction without reserve is a unilateral offer by the auctioneer to accept the highest bid, however unreasonable. The plaintiff bid 200 each for two engine analysers, market value over 14,000. The auctioneer refused to accept. It was held that he was liable for the difference between the bid and the market value.

Barry v Davies [2000] 1 WLR 1962 is an English contract law case concerning an auction. The auctioneer withdrew goods from an auction (the goods had no reserve price) when a bona fide bid of £200 was effective. The court held that an auctioneer is bound to sell to the highest bidder where there is no reserve price, and can't withdraw the sale simply because the price is too low. A bid in an auction, the possibility of acceptance of the bid, unless the bid is withdrawn, and the benefit to the auctioneer of driving up the price bid is sufficient consideration. The contract in an auction is between the buyer and the seller, not the buyer and the auctioneer, although the buyer has a collateral agreement with the auctioneer.

Remedy is the difference between the contract value, and the current market value of the goods under the Sale of Goods Act 1971 s51(3). The value in this case was £27,600.