Counter - offer and Death - Termination of an Offer
Counter - offer
However a counter - offer is constituted through the offeree's qualified acceptance that in itself grow to be the fresh offer and cancels the original offer like e.g. of Hyde v. Wrench - in whether the "acceptance" for buy the house to £950 was held to have cancelled the offer to sell whereas at £1,000.
Death
Well the death of either party previous to acceptance terminates a specific offer. Conversely the offer only lapses whether notice of death of the one is given for the other. Thus as was the case in the Bradbury v Morgan Mellish Js dictum in Dickinson V Dodds is then emphatic after the offeror dies his offer cannot be accepted.