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Wrongful Dismissal and Constructive Dismissal
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A family-owned manufacturing company in southwestern Ontario had employed a production manager for 14 years when the ownership passed from the founder to the founder's adult children following the founder's retirement. The production manager had joined the company at age 38, working initially as a floor supervisor before being promoted to the management role 9 years into his tenure. His responsibilities had expanded over time to include scheduling, quality control oversight, and direct supervision of 22 production staff. The employment relationship had never been governed by a written contract, and the company had no formal policies addressing termination procedures, severance entitlements, or the circumstances under which employment might end.

Within 8 months of the ownership transition, the new leadership decided to restructure operations. The restructuring plan called for consolidating the production manager's role with that of the logistics coordinator, creating a single position with a significantly altered scope of duties, a different reporting structure, and a reduction in supervisory responsibility from 22 staff to 6. When presented with the proposed changes, the production manager was given 2 weeks to accept the new role or face termination. The new position would have required him to report to a newly hired operations director rather than directly to ownership, would have eliminated his quality control responsibilities entirely, and would have reduced his annual compensation by approximately 18 percent.

The production manager declined the restructured position and was terminated without cause. The company offered him 8 weeks of pay in lieu of notice, calculated on the basis of the statutory minimum under provincial employment standards legislation, plus an additional 2 weeks as a gesture of goodwill. The offer was conditional on his signing a release that would extinguish any further claims arising from his employment or its termination. The production manager was given 5 business days to accept the offer, with no suggestion that he seek independent legal advice before signing.

The production manager did not sign the release within the deadline. Instead, he retained employment counsel, who sent a demand letter asserting that the offer was grossly inadequate given his length of service, age at termination (then 52), and the specialized nature of his role in a niche manufacturing sector. The demand letter also alleged that the proposed restructuring itself had constituted constructive dismissal before the formal termination occurred. The company's response denied any wrongdoing and maintained that the severance offer was reasonable. The dispute escalated to litigation, requiring the company to defend its termination process, justify its notice calculation, and respond to claims for damages that extended well beyond the initial offer.

The Duty to Mitigate: What the Employee Must Do and How It Affects Recovery

The duty to mitigate stands as one of the most practically significant yet frequently misunderstood principles in Canadian employment law. When an employer terminates an employee without just cause and without providing adequate notice or pay in lieu thereof, the employee becomes entitled to damages representing the compensation they would have earned during a reasonable notice period. However, this entitlement does not operate as an unconditional right to sit at home collecting damages while making no effort to find alternative employment. Canadian law imposes upon every dismissed employee an obligation to take reasonable steps to minimize their losses, and failure to fulfill this obligation can substantially reduce the damages an employer must ultimately pay. For business owners, sole proprietors, and non-profit operators across Canada, understanding how the duty to mitigate functions is essential both for managing the aftermath of terminations and for assessing realistic exposure to wrongful dismissal claims.

The foundation of the duty to mitigate rests in fundamental principles of contract law that apply across all common law provinces in Canada. When one party breaches a contract, the innocent party cannot simply allow their damages to accumulate indefinitely without making reasonable efforts to reduce those losses. Employment relationships, though governed by their own specialized body of law, remain at their core contractual arrangements, and the same mitigation principles apply. The rationale is straightforward and grounded in fairness: an employee who has been wrongfully dismissed has suffered a legal wrong, but society and the courts do not expect that person to remain passive while damages mount when alternative employment might be available. The duty recognizes that both parties have interests worth protecting. The dismissed employee deserves fair compensation for the breach of their employment contract, while the employer should not be forced to pay for losses that the employee could reasonably have avoided through diligent job search efforts.

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