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(1858) 1 EE 309; 120 ER 925. When an item is advertised in an auction without reserve, then the usual auction rule applies, that a bid is an offer and it can be accepted or declined. However, there is a further, unilateral offer, by the auctioneer to whomever turns out to be the highest bidder. That offer is to accept the highest bid. Therefore, the auctioneer can be sued if he does not accept the highest bid.

In this case the plaintiff bidder lost the case on a technicality, and the decision on the unilateral nature of the without reserve auction was therefore obiter. However, it was followed in Barry vdav ies (2000).