able to stand for the by-election; this is the traditional method of resigning from Parliament, since MPs are not permitted to hold most positions in the gift of the Crown without approval from their constituencies. Immediately after the announcement, Labour announced they would not field a candidate. On 19 June, comments by Culture Secretary Andy Burnham contrasting Davis's past political record on libertarian issues, with the views of Liberty director Shami Chakrabarti, whom Davis asked for advice prior to his resignation, brought a threat of litigation from Chakrabarti to Burnham pending an apology. On 20 June, in an appearance on the panel of Question Time, Davis conceded that he was unlikely to be "offered his job (in the shadow cabinet) back" and the likely setback to his political career was a "cost he would have to bear" as a result of his decision to resign. On 11 July, Davis was subsequently re-elected to his seat with 72% of the vote. Davis received 17,113 votes, with the closest challenge coming from the Green Party and English Democrats with 1,758 and 1,714 votes respectively. All other candidates lost their deposit due to polling less than 5% of the vote. In his acceptance speech after the by-election, Davis stated that "today is not the end of this campaign", pledging to continue campaigning against 42-day detention, ID cards and governmental invasion of privacy. Davis returned to Parliament as a backbencher, with no immediate likelihood of a return to the Shadow Cabinet. Reaction While the Conservative party voted against the 42 day extension in the initial poll, in the days following his resignation, Davis's move was characterised by Conservative party leader David Cameron as a "very courageous and brave" decision, but a "personal decision, and not one of the Shadow Cabinet or Conservative Party", although the Daily Telegraph newspaper claimed that Cameron believed it was unnecessary for Davis to resign, and had clearly told Davis of his view. Liberty director Shami Chakrabarti described the move as "very brave". Davis's Campaign Manager in the 2005 Conservative leadership contest, Andrew Mitchell (who in 2010 became the Secretary of State for International Development), although remaining a strong supporter of Davis, was reported by the media to have met him on the House of Commons terrace and was seen to have "looked horrified" when Davis told him of his decision, and to have vigorously argued with him about it.