Unjust dismissal canada labour code. 240 - DIVISION XIV - Unjust Dismissal; 246.

Unjust dismissal canada labour code Section 240 of the Canada Labour Code (the Code), Part III (Standard Hours, Wages, Vacations and Holidays), protects against unjust dismissal for federally regulated employees who have completed at least 12 months of continuous employment with the same employer and who are not covered by a collective Canada Labour Code Employees; Layoffs; Human Rights In The Workplace; Workplace Harassment; Employment Contracts; Some forums impose tight timelines, for instance under the CLC there is a 90-day deadline to file an unjust dismissal claim or 6 months to file a labour standards complaint through Employment and Social Development Details; Number: LAB1190: Title: Complaint Form - Unjust Dismissal: Purpose: This form is used by the public to file an unjust dismissal complaint under the Canada Labour Code, Part III (Labour Standards) and must be submitted to start an inspection by a Labour Affairs Officer. ca/federal-labour-standards or contact the Labour Program 1-800-641-4049 Teletypewriter (TTY) 1-800-926-9105 Division XIV - Unjust Dismissal of Part III of the Canada Labour Code The length of time required to resolve a complaint varies depending on the case. For more information, reach out to our team of lawyers at 705-268-6492. Overview. The Amending Regulation revises the Canada Labour Standards Regulations, the Standards for Work-Integrated Effective date: September 25, 2000. of an unjust dismissal, a federal Labour Affairs Officer will try to settle the complaint. 1 - [Repealed, 2018, c. ” Federally regulated employees may initiate an unjust dismissal claim where they: Atomic Energy of Canada Limited, 2016 SCC 29, the Supreme Court of Canada (“SCC”) concluded that the unjust dismissal provisions, sections 240 to 246, of the Canada Labour Code (“Code”) displace the ability of employers at common law to dismiss federally-regulated employees without cause. Generally speaking to be excluded from this remedy, a “manager” must have independent decision-making authority. The provisions as found in the Canada Labour Code regarding an unjust termination are as follows: Division XIV Unjust Dismissal. PROTECTED WHEN COMPLETED - B. #LabourStandards @Labour_ESDC Did you know The unjust dismissal provisions in the Canada Labour Code provide certain employees with protections similar to those protections given to unionized employees under collective agreements. Unjust Dismissals under the Canada Labour Code The law of unjust dismissals in federally regulated workplaces. 1 - Complaints Relating to Reprisals; 247 - DIVISION XV - Payment of Wages; In a decision which returns us to what many thought was the status quo, the Supreme Court of Canada has ruled that, (save for exempt employees), the unjust dismissal scheme in the Canada Labour Code (the “Code”) does not permit federally regulated employers to dismiss employees without cause once they have one year of service or more. 22, s. Under Section 240 of the CLC, an employee may file Reagan Ruslim, "Unjust Dismissal Under the Canada Labour Code: New Law, Old Statute", (2015) 5:2 online: UWO J Leg Stud 3. Unjust Dismissal Canada Labour Code Part III . S. unjust dismissal In the recent decision of Maninderpal Randhawa and The Bank of Nova Scotia (February, 2017) under Part III of the Canada Labour Code (the “Code”), Adjudicator Slotnick determined that reinstatement was the proper remedy after finding that the employee’s dismissal was unjust. 1 - DIVISION XV. Close. If he or she is unable to achieve a settlement, the employee has the right to request that the complaint be sent to What is unjust dismissal? According to legislation under the Canada Labour Code (CLC) an unjust dismissal is a type of legal claim that strictly applies to non-unionized employees working for a federally regulated company in Canada who have been fired in a manner they feel to be unjust or arbitrary. Previous Versions. Revised date: June 20, 2024. The Code permits a dismissed employee to file a complaint, pursuant to s. It allows them to seek extraordinary remedies, "Division XIV – Unjust Dismissal of Part III of the Canada Labour Code provides a procedure for making complaints against a dismissal that an employee considers to be unjust. If such an employee is dismissed and the dismissal is unjust, Division XIV – Unjust Dismissal of Part III of the Canada Labour Code provides a procedure for making complaints against a dismissal that an employee considers to be unjust. Who Qualifies. 240(3) Extension of time. DATE STAMP . Wilson overturned decades of jurisprudence regarding unjust dismissal and interpretation of the Canada Labour Code. (1) Subject to subsections (2) and 242(3. The following Under the Canada Labour Code, Unjust Dismissal rules provide a procedure for federally regulated employees to complain against a termination that they consider unjust. Atomic Energy of Canada Limited, the Federal Court of Appeal has The Federal Court of Appeal recently released an important decision that clarifies the law relating to unjust dismissals under the Canada Labour Code (“Code”). This is powerful legal remedy which may lead to Federal laws of Canada. After investigating a complaint . au r ogr am ˜˚˛˝˙ˆˇ˘ ˝˚ ˝˚ fifl fifi˘ 8 Unjust Dismissal LT-035-06-18E Part III of the Canada Labour Code (Labour Standards) Division XIV – Unjust Dismissal of Part III of the Canada Labour Code provides a procedure for making complaints against a The Canada Labour Code's provisions for addressing alleged wrongful dismissal are unique. 1), the Board, after a complaint has been referred to it, shall (a) consider whether the dismissal of the person who made the complaint was unjust and render a decision thereon; and (b) send a copy of the decision with the reasons therefor to complaint under Division XIV of the Canada Labour Code. The Canada Labour Code, Part III sets out rights on termination of employment and governs Individual Termination of Employment, Severance Pay, Unjust Dismissal and Group Division XIV – Unjust Dismissal of Part III of the Canada Labour Code provides a procedure for making complaints against a dismissal that an employee considers to be unjust. 354] Marginal note: Decision of the Board (3) Subject to subsection (3. L-2. BEFORE FILING A COMPLAINT • An Unjust Dismissal complaint is admissible if you: o have Canada Labour Code, Part III (Labour Standards) DATE STAMP. 240. They also offer a way for employees to recover unpaid wages and ensure other The unjust dismissal sections of the Canada Labour Code ("Code") were, at one time, thought to have provided enhanced job security for non-unionized individuals employed in the federal sector by significantly narrowing the circumstances in which an employer could discharge an employee. Subject; Issue; Interpretation; Examples; Subject. It provides minimum employment standards and rules about occupational health and safety, amongst others. The provisions of the Code set basic employment conditions in federally regulated workplaces. and The Bank of Nova Scotia, Re, 2020 CarswellNat 640, Adjudicator Kaufman considered the issue of whether the Canada Labour Code (the The issue in this case centered on an adjudicator's jurisdiction when the parties have entered into a valid and enforceable employment contract allowing for 'without cause' termination. Section 240(1) of the Canada Labour Code provides that a person who has been dismissed and considers the dismissal to be unjust, may make a complaint in writing, only if. FOR INTERNAL USE ONLY. Unjust Dismissal Under the Canada Labour Code: New Law, Old Statute Abstract In Atomic Energy of Canada Ltd v Wilson (Wilson), the Federal Court held for the first time that an employer The decision of the Federal Court of Appeal in Bank of Montréal v Yanping (Kate) Li, 2020 FCA 22, provides an interesting take on the settlement of a dismissal under the jurisdiction of the Canada Labour Code (the “Code”) prior to a complaint of unjust dismissal being filed that federally regulated employers should be wary of. The decision follows the principles set out by the Supreme Court of Canada [] Complaint Form - Unjust Dismissal: LAB1196: Labour Standards : Report to the Head of Compliance and Enforcement Pursuant to Subsection 175 (5) of the Canada Labour Code, Part III: ESDC-LAB1197: Labour Standards : Notice to the Head of Compliance and Enforcement of a group termination of employment and request for waiver under the Canada Labour Unjust Dismissal – Canada Labour Code – In the matter of an appeal under Part III of the Canada labour Code BETWEEN: MALASPINA COACH LINES LTD. This decision follows the Board’s decision in Saunders v WestJet, which was the focus of an earlier blog post Unjust Dismissal. On this page. This means that complaints filed on or after July 29, 2019, will be referred by the Labour Program to the CIRB for resolution instead of an adjudicator. What is unjust dismissal? For federally regulated employees, there is a right in the Canada Labour Code that they can claim for unjust dismissal. The remedies for unjust dismissal are only available to employees who have completed a minimum of twelve consecutive months of continuous While most employees in Canada who seek damages for being dismissed from their job unfairly will bring an action for wrongful dismissal, those who are employed in federally-regulated industries have a unique scheme to follow. HTML Full Document: Canada Labour Code (Accessibility Buttons available) | XML Full Document: Canada Labour Code [1429 KB] | 240 - DIVISION XIV - Unjust Dismissal; 246. an unjust dismissal or genetic testing complaint within the 90-day time limit ; On September 3, 2010, the Minister of Labour appointed me as the adjudicator to hear Ms. [47] Some agree with the adjudicator and the appellant in the case at bar and have concluded that the Code does not permit dismissals on a without cause basis: see, e. This relief is available only to those persons employed in federally regulated businesses. Pamphlet 1 – Summary of this series describes the types of businesses covered Notice relating to the Canada Labour Code – Part III; Progressive discipline; Report of the Expert Panel on Modern Federal Labour Standards; Unjust dismissal; Unjust dismissal – A guide to the hearing process; Unjust dismissal – Mediation process; Wage Earner Protection Program – A program to protect workers’ wages 1 The Canada Labour Code sets out minimum employment standards, and a unique unjust dismissal regime that applies only to federally regulated employers. 2 2010 FC 105. ” Historically, the unjust dismissal provisions of the Code have been interpreted to Supreme Court of Canada Majority Rules “Unjust Dismissal” Provisions of Canada Labour Code Prohibit Without Cause Dismissals of Non-Unionized Employees Date: July 14, 2016 In an important decision for federally regulated employers, Wilson v. Unjust Dismissal Complaints Under The Canada Labour Code; Wrongful Dismissal Litigation; Workplace Immigration. Applying the following provisions in Part III of the Canada Labour Code (Code) to cases of constructive dismissal:. If successful, a claim for unjust dismissal may entitle an employee to reinstatement. BEFORE FILING A COMPLAINT • A . 1(1) of the Code) or an unjust dismissal complaint (240(1) of the Code) has already been filed, that is based on substantially the same facts, conditions for fi ling an unjust dismissal complaint. (246. An employer must have “just cause” to terminate employment, otherwise, the Part III of the Canada Labour Code (Labour Standards) Employee terminations are regulated under Part III of the Canada Labour Code in regard to Individual Termination (notice), Severance Pay, Unjust Dismissal and Group Termination. If the Inspector determines that the complaint is Reagan Ruslim, 2015 5-2 Western Journal of Legal Studies, 2015 CanLIIDocs 375 The Code was amended in 1978. Date: November 28, 2023 Amendments to the Canada Labour Code (Code) which come into effect on February 1, 2024 will require employers to provide individual employees with a graduated notice of termination Unjust dismissal is a cause of action available under the Canada Labour Code to federally regulated employees who feel that they have been terminated in a manner that is unfair, unjust, or arbitrary. They also offer a way for employees to recover unpaid wages and ensure other labour standards protections are upheld in their workplace. The Canada Labour Code offers a unique remedy of “unjust dismissal” to non-union employees who are also “non-managers” with more than 12 months of employment history. Share with your friends and colleagues Pick one or more destinations: 0. Développement social Canada. 16] Ontario Hydro Nuclear Facilities Exclusion from Part II 1 The Canada Labour Code sets out minimum employment standards, and a unique unjust dismissal regime that applies only to federally regulated employers. The Canada Labour Code provides a process to address federal labour standards complaints. In doing so, the Court has settled the long-standing debate What is a complaint of unjust dismissal. A federally regulated employee who has been dismissed for cause from 1. 240(2) Time for making complaint. L-2 (the “Code“) only provided non-unionized federally The Code prescribes a minimum notice period and states that an employee, af ter serving three consecutive months of continuous employment is entitled to at least two weeks’ notice or 2 weeks’ pay in lieu of notice. Background The Supreme Court of Canada has issued a landmark employment law decision. Unjust Dismissal Under Canada Labour Code. The Canada Labour Code provides legal protection to employees in federally regulated workplaces and outlines various obligations an employer must comply with during a termination. In a nutshell, the Supreme Court has held that the vast majority of federally regulated employees can access the unjust dismissal provisions of the Code. Featured Articles. 01) For greater certainty. The following questions, answers and case studies will be of interest to employers and employees under federal jurisdiction. This paper critically reviews Wilson For a long time, adjudicators acting under the Code have disagreed on whether Part III of the Canada Labour Code permits dismissals on a without cause basis. Wallace Part 2 Damages for Tangible Financial Loss dqh September 6, 2023 An important feature of Wallace is that the notice period was extended not solely to compensate Wallace for emotional suffering. Sandhu under the Canada Labour Code, R. COMPLAINT FORM - UNJUST DISMISSAL. 1), any person The Canadian Industrial Relations Board has released new decisions concerning the “managerial exception” found in section 167(3) of the Canada Labour Code – a provision which excludes “Managers” from the Code’s unjust dismissal regime. Previous Page Table of Contents Next Page. The decision affects thousands of employees working in federally regulated industries, as it means that employers may dismiss non-union employees without cause, so long as reasonable notice is FTR Now Supreme Court of Canada Majority Rules “Unjust Dismissal” Provisions of Canada Labour Code Prohibit Without Cause Dismissals of Non-Unionized Employees. Atomic Energy of Canada Limited, a majority of the A review of the issue of manager which position is excluded from the right to use the Unjust Dismissal remedy under the Canada Labour Code. While the Canada Labour Code does not explicitly define the term “unjust,” common law dictates that federally regulated employees can generally only be dismissed for complaint under Division XIV of the Canada Labour Code. It is brought by Ms. Date: July 14, 2016 In an important decision for federally regulated employers, Wilson v. L-2). For our clients in the federal sector, we often receive questions about the unjust dismissal provisions in the Canada Labour Code (the “Code”). Author: Charles Muriithi In the 16 March 2022 issue of the Canada Gazette, the Federal Government filed the Regulations Amending Certain Regulations Made Under the Canada Labour Code, SOR/2022-41 (the “Amending Regulation”). Complaint to inspector for unjust dismissal. 0. Arlene Morrison’s complaint of unjust dismissal by the Band (Section 240 of the Canada Labour Code, R. 1985, c. Search for: 877-296-1161. Employment and Social Development Canada. Air transportation Banks. 2 With its decision in Wilson v. 240 of the Code, with the Ministry of Labour if they believe their dismissal was 'unjust'. Careers; Blog; FAQs; Events On July 14, 2016, the Supreme Court of Canada decided that the “Unjust Dismissal” sections of the Canada Labour Code ensure that non-unionized federal employees are protected from termination of their employment without I have just issued a similar decision about progressive discipline and termination of an employee under the Canada Labour Code. Chart of Human Rights Damage Awards. The case of Wilson v. Sections 240 to 246 introduced a procedure that enabled federally non-unionized workers to seek redress in cases where they have been dismissed without just cause, which the Code refers to as “unjust dismissal. Violet X against YIndependent School Society (“CISS,” the “Society” or the “Employer”) with Unjust dismissal complaints, Section 240 of the Canada Labour Code: The CIRB now has responsibility for adjudicating unfair dismissal complaints. 1) Limitation. 240(1. What’s New. C. The following questions and answers will be of interest to employers and employees under federal jurisdiction. First Nation Band Councils and federal Crown corporations such as Canada Post An Act to amend the Canada Labour Code, the Parliamentary Employment and Staff Relations Act, the Public Service Labour Relations Act and the Income Tax Act (Bill C-4, DIVISION XIV — Unjust Dismissal [240 - 246] 240 Complaint. The purpose of the Unjust Dismissal scheme in the Canada Labour Code was to provide federally regulated, non-unionized employees with protection against arbitrary dismissal in a manner which essentially matched You must file your unjust dismissal complaint with the Labour Program of Employment and Social Development Canada. Every unjust dismissal complaint must meet the criteria set out in Division XIV of the Code. Introduction . Atomic Energy of Canada Limited, a majority of the Supreme Court of Canada has found the “unjust dismissal” In P. Unjust Dismissal Under the Canada Labour Code: New Law, Old Statute Abstract In Atomic Energy of Canada Ltd v Wilson (Wilson), the Federal Court held for the first time that an employer Canada Labour Code Unjust Dismissal. Publication 8 – Unjust Dismissal outlines who is entitled to protection from unjust dismissal, how to register a complaint of unjust dismissal and provides case studies based on actual unjust Canada Labour Code: Unjust Dismissal Update Noëlle Caloren Senior Legal Counsel, Labour & Employment 2024 May 08. Marginal note: Complaint 240 (1) Subject to subsections (2) and 242(3. and For copies of the Code and the Canada Industrial Relations Board Regulations, 2012 (the Regulations), rules of procedure, 12 consecutive months or more, was not subject to a collective agreement and was not a manager must file a complaint of unjust dismissal with the Labour Program within 90 days of dismissal. worked as a customer service representative at the Bank of Nova Scotia (the "employer"). For more information: Canada. In P. 20, s. She was Reagan Ruslim, "Unjust Dismissal Under the Canada Labour Code: New Law, Old Statute", (2015) 5:2 online: UWO J Leg Stud 3. For example, the Inspector will verify whether the employer is covered by the Canada Labour Code, whether the employee has enough continuous employment time (12 months) and whether the complaint has been fi led within 90 days of the dismissal. UNRESTRICTED / ILLIMITÉE 3 Unjust Dismissal Basics •Employees under the Code may make a complaint if they believe their dismissal was “unjust”. In its decision in Wilson v. 240 - DIVISION XIV - Unjust Dismissal; 246. 3 Unjust dismissal admissibility criteria (10) The Supreme Court of Canada recently overturned a controversial decision of the Federal Court of Appeal (Koskie Minsky LLP Employment Blog February 9, 2015). In the outcome of this case, the Supreme Court of Canada indicated that non-unionized employees working for a federally regulated entity who can pursue an unjust dismissal claim under the Canada Labour Code can only be dismissed if the employer has “just cause. 1), a person who has been dismissed and considers the dismissal to be unjust may make a complaint in writing to the Head if the employee (a) has completed 12 consecutive months of continuous employment by an employer; and (b) is not a member of a group of employees PDF Full Document: Canada Labour Code [2343 KB] Act current to 2024-11-26 and last amended on 2024-06-20. The following questions, answers and case studies will be of interest to employers and employees under federal Part III of the Canada Labour Code provides workers and employers under federal employment. UNRESTRICTED / ILLIMITÉE 2 Unjust Dismissal Overview SECTION 1. Unjust dismissal complaint and Genetic testing complaint. 354] (2) [Repealed, 2017, c. Atomic Energy of Canada Limited, has potentially changed the game for federally-regulated employers. ” Historically, the unjust dismissal provisions of the Code have been interpreted to At SD Law, we are available to support employees and employers with all employment related matters, including unjust dismissal concerns and termination under the Canada Labour Code. In my decision, the employee was discipline free for over four years A recent decision by the Federal Court of Appeal, Wilson v. She was In coming to this conclusion, he noted that the unjust dismissal provision in Part III of the Canada Labour Code is intended to allow non-unionized workers who have been unjustly dismissed to benefit from protections similar to those available to unionized employees under a collective agreement. Employer Obligations During Termination. 778-653-7561. Part III of the Canada Labour Code (the Code) establishes and protects the rights of workers in federally regulated industries and workplaces to fair and equitable conditions of employment. After you file a complaint, JURISDICTIONAL DECISION. g. This is a right that is in addition to potentially being allowed for reasonable common law notice and allows the employee to ask for their job back. This an unjust dismissal complaint under the Canada Labour Code, R. Pamphlet 8 – Unjust Dismissal outlines who is entitled to protection from unjust dismissal, how to register a complaint of unjust dismissal and provides case studies based on actual unjust dismissal The Canada Labour Code (the “Code”) regulates federal workplaces. Publication 8 – Unjust Dismissal outlines who is entitled to protection from unjust dismissal, how to register a complaint of unjust dismissal and provides case studies based on actual unjust On January 22, 2015, the Federal Court of Appeal rendered an extremely important decision, 1 unanimously holding that dismissal on a without cause basis does not necessarily constitute “unjust dismissal” under the Canada Labour Code (the “Code”). Specifically, the Federal Court of Appeal held that “Unjust Dismissal” provisions pursuant to sections 240 to 246 of the Canada Labour Code, R. The Basics The Canada Labour Code Remedy What is Unjust Dismissal and Who Does it Apply to? The Unjust Dismissal provisions under Part III of the Canada Labour Code apply to and protect all employees who work for federally regulated employers, including, but not limited to:. This is powerful legal remedy which may lead to Unjust dismissal under CLC encompasses both wrongful dismissal and constructive dismissal under common law. The complainant P. Atomic Energy of Canada Ltd. 1 - DIVISION XIV. In a constructive dismissal, the employer has not directly fired the employee, but has failed to comply with the contract of Mediation assistance is available to employers and complainants involved in an unjust dismissal complaint under Division XIV of the Canada Labour Code. 3 The test set out in this article pertains only to the factors considered whether an employee is a manager for the purposes of the Canada Labour Code. Unjust dismissal outlines who is entitled to protection from unjust dismissal, how to register a complaint of unjust dismissal and provides 242 (1) [Repealed, 2017, c. 1 - Complaints Relating to Reprisals; 247 - DIVISION XV - Payment of Wages; 247. Unjust Dismissal . J. Wilson was an employee of [] Under the Canada Labour Code (“CLC”), unjust dismissal is not defined, however, it is a complaint process for non-unionized federal employees who feel that their dismissal was unjust. . In Wilson v Atomic Energy, 2015 FCA 17, the Court overturned a labour adjudicator’s decision that any dismissal without cause under the Codewas an unjust dismissal. A recent decision of the Federal Court of Canada illustrates the tremendous power of the Unjust Dismissal remedy under the Canada Labour Code. Canada Labour Code, Part III (Labour Standards) - DIVISION XIV. The Band terminated her employment The Code was amended in 1978. 2. Under the Code, federally regulated employees in non-management positions with more than 12 months of service are protected from unjust dismissal. 1 - Complaints Relating to Reprisals; 247 - DIVISION XV - Payment of Wages; Federal Judge Reviews Unjust Dismissal Remedy. , Re Roberts and the Bank of Nova Scotia 1 By letter dated September 3, 2014, I was appointed by the Minister of Labour to hear and adjudicate the unjust dismissal complaint filed by Ms. Share . 2 Employees who believe they have been unjustly dismissed may lodge a written complaint of unjust dismissal with the department, subject to admissibility. The Code imposes a very high threshold on employers about how and when they can dismiss their employees. Atomic Energy of Canada focused on the definition of “unjust dismissal” under Part III of the Canada Labour Code. Rather than “wrongful dismissal”, the Canada Labour Code (the “Code”) offers the remedy of unjust dismissal to all non-managerial 240 - DIVISION XIV - Unjust Dismissal; 246. Part III of the Canada Labour Code (Labour Standards) Division XIV – Unjust Dismissal of Part III of the Canada Labour Code provides a procedure for making complaints against a dismissal that an employee considers to be unjust. Employees. complaint under Division XIV of the Canada Labour Code. If the employer does not have cause for dismissal, it is an “unjust dismissal” and you can seek reinstatement to your job and/or damages. The courts have held that the unjust dismissal provisions of Part III of the Canada Labour Code also apply to "constructive dismissal". Federal Post Reminder: Significant Amendments to the Termination Provisions of the Canada Labour Code Are Coming Into Effect on February 1, 2024. D. The following What is Unjust Dismissal and Who Does it Apply to? The Unjust Dismissal provisions under Part III of the Canada Labour Code apply to and protect all employees who Federally regulated employees or employees who work with a federally regulated employer are protected under the Canada Labour Code ("the Code") which has strict Generally speaking to be excluded from this remedy, a “manager” must have independent decision-making authority. FOR OFFICE USE ONLY . However, an employee who a) has more than 12 months of service; b) is not a manager; and c) works for a federally-regulated employer covered by the Canada Labour Code cannot be dismissed without just cause. , the Supreme Court of Canada (SCC) has ruled that federally-regulated employers subject to the Canada Labour Code (Code) are not permitted to dismiss employees on a without cause basis, with a few exceptions provided for under the Code (discussed below). This blog is co-written by our former articling student, Janet Son. and The Bank of Nova Scotia, Re, 2020 CarswellNat 640, Adjudicator Kaufman considered the issue of whether the Canada Labour Code (the "Code") authorized adjudicators to award costs in unjust dismissal cases. L-2 (the “Code”), dated January 24, 2014. , Appellant AND: CHRISTINA S. For these protections to apply: the employment relationship must be federally regulated (such as most employees of Band councils and First Nations); The provisions of the Code set basic employment conditions in federally regulated workplaces. Malaspina Coach Lines Ltd. There are timeframes that need to be followed and they vary depending on the type of complaint. You do this by filling out and submitting a complaint form to them. In Atomic Energy of Canada Ltd v Wilson (Wilson), the Federal Court held for the first time that an employer may terminate an employee without cause, so long as the employer provides notice or severance pay. 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