An offer must be unconditionally and unqualified by accepted. Any addition to or subtraction from the terms of the offer is an alteration to the terms and amounts to a total rejection of the offer by the offeree. The terms embedded in the rejection may form the basis for the formation of a new agreement. This is what amounts to a counter-offer. An offer is impliedly rejected if the offeree instead of accepting the original offer makes a counter-offer which varies the terms proposed by the offeror. Hyde v. Wrench (1840) 3 Kear. 334.
— Adekeye, JSC. Best Ltd. v. Blackwood Hodge (2011) – SC