Tory leader David Cameron has praised David Davis for his by-election victory but is refusing to say whether he will offer him another frontline role.
He called the former shadow home secretary a "very strong" figure who could "contribute in the future".
But Mr Cameron added that he already had a "very strong shadow cabinet".
Mr Davis won Haltemprice and Howden on a civil liberties platform, with a majority of 15,355. Labour and the Lib Dems did not put up candidates.
'Made his point'
And Home Office minister Tony McNulty reacted to the result by accusing Mr Davis of "vanity" and comparing him to the hapless cartoon character Homer Simpson.
Mr Davis quit as an MP in June over the government's plans to detain terror suspects for up to 42 days without charge.
At the time, Mr Cameron stressed it was his personal decision - and swiftly moved to replace him as shadow home secretary with shadow attorney general Dominic Grieve.
We have fired a shot across the bows of Gordon Brown's arrogant, arbitrary and authoritarian government David Davis MP |
Mr Davis, who will return to the Commons as a backbencher, said he did not plan to become a "single-issue campaigner" on civil liberties.
Asked if the Haltemprice and Howden MP will be given another shadow cabinet role, Mr Cameron said: "He can contribute in the future... I think he's made his point in the way that he wanted to.
"What matters is what's right and standing up and saying what's right as the Conservative Party, throughout this whole argument, has done."
'Authoritarian government'
Mr Cameron added: "I will obviously talk to him about what the future holds, but I've got a very strong shadow cabinet. David is a very strong Conservative figure.
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"I'm sure there will be many ways he can contribute in the future."
Mr Davis, who was beaten by Mr Cameron in the contest to become party leader in 2005, said: "We have fired a shot across the bows of Gordon Brown's arrogant, arbitrary and authoritarian government."
He said he would return to Westminster on Monday with a mandate "to fight Gordon Brown's vision of Big Brother Britain tooth and nail, to stop 42 days in its tracks, to prevent the disaster of ID cards before it happens, to protect our personal privacy from being ransacked by the ever-intrusive state".
Mr Davis is expected to discuss his future role, if any, with Mr Cameron after he returns but he admitted it was unlikely the Tory leader would invite him back onto the party's front bench.
'Cowardice'
"I took on board that I would lose my shadow cabinet post and probably my shadow cabinet future," he said. "I accept that."
Mr Davis promised to "put a lot of effort" into opposing 42 days' detention on his return to Parliament.
He told BBC Radio 4's Today programme: "The trouble with this is, from the beginning, the Westminster village hasn't really understood that someone wants to take a stand on a matter of principle that may have some effect on themselves."
Mr Davis also accused the government of "spectacular cowardice" for not fielding a candidate.
But Mr McNulty accused Mr Davis of "vanity" for prompting a by-election, saying: "It doesn't need David Davis to give the country his permission to have a debate on the issue (of 42 days' detention)."
'Lonely stand'
He added that Mr David should have remained an MP to "make the arguments" in Parliament.
In light of Gordon Brown's recent admission that it was "absolutely correct" to compare himself to Heathcliff, the romantic hero of the novel Wuthering Heights, Mr McNulty was asked who Mr Davis reminded him of.
He replied: "David Davis? Probably Homer Simpson."
Liberal Democrat leader Nick Clegg said: "The Conservatives are a long way from being defenders of liberty.
What has the David Davis by-election result achieved? Absolutely nothing!
"David Davis' lonely stand only highlights the big questions that still remain over whether the Conservatives really are committed to protecting our freedom."
Turnout in Haltemprice and Howden was 34%, with the Green Party coming second on 1,758 votes and the English Democrats third on 1,714.
Out of a record 26 by-election candidates, 23 lost their deposits after failing to attract 5% of the vote.
At the last general election Mr Davis won the seat with a 5,116 majority.
However, the 17,113 votes he polled were fewer than the 22,792 he achieved at the 2005 election, and turnout was also down from 70.2%.
The Lib Dems - who came second in 2005 - chose not to run because they also opposed the government's plans to extend the time limit on holding terrorism suspects.
Labour refused to stand, describing the by-election as a farce and a waste of more than £80,000 of public money.
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