"Where an offer is made but is not accepted, there can be no agreement/contract arising therefrom.

On the other hand, where an offer is made but not accepted in the form it was made or where fresh proposals demanding to be considered by the offeror before agreeing thereto are made by the offeree, then there is no acceptance of the offer as made because what the offeree has done amounts in law to making a counter offer, which does not translate to an acceptance."

Per ONNOGHEN, J.S.C. in Bilante International Ltd. V. Nigeria Deposit Insurance Corporation (2011) 6-7 SC (Pt. IV) 113 60.