Can a counter offer constitute a rejection of an offer?

It is common ground that, as a general rule, a counteroffer may, and indeed generally does, constitute a rejection of the offer and terminate it so that it is no longer open for acceptance. See Chitty on Contracts, 27th ed., para. 2-063 [vol. 1, p. 128]: A rejection terminates an offer, so that it can no longer be accepted. For this purpose, an attempt to accept an offer on new terms (not contained in the offer) may be a rejection accompanied by a counter-offer. Thus in Hyde v. Wrench the defendant offered to sell a farm to the plaintiff for £ 1,000. The plaintiff replied offering to buy for £ 950, and when that counter-offer was rejected, purported to accept the defendant's original offer to sell for £ 1,000. It was held that there was no contract as the plaintiff had, by [Page 44] making a counter-offer of £950, rejected, and so terminated, the original off.