A-1363-84 
Slaight Communications Inc. (Operating as Q107 
FM Radio) (Applicant) 
v. 
Ron Davidson (Respondent) 
Court of Appeal, Urie, Mahoney and Marceau 
JJ.—Toronto, March 25; Ottawa, April 23, 1985. 
Labour relations — Unjust dismissal — Adjudicator order
ing applicant to give respondent letter of recommendation 
containing express statements of fact, and ordering future 
inquiries be answered only by delivery of copy — Adjudicator 
retaining jurisdiction to decide dispute over implementation of 
order — Adjudicator within authority under s. 61.5(9) of Code 
— Purported retention of jurisdiction superfluous since Fed
eral Court of Appeal holding in Huneault v. General [sic] 
Mortgage and Housing Corporation that retention not giving 
Adjudicator power to reconsider, withdraw or change order — 
Inclusion of superfluous order not vitiating decision — S. 
61.5(9) giving Adjudicator power to order payment of compen
sation, reinstatement or "any other like thing ... in order to 
remedy or counteract any consequence of dismissal" — Inclu
sion of "like" not intended to restrict remedial action to 
something akin to compensation or reinstatement — National 
Bank of Canada v. Retail Clerks' International Union distin
guished because there employer required to express opinions 
not held — Order requiring provision of factual letter and 
foreclosing foreseeable undermining of effect, equitable 
remedial requirement — Application for review dismissed with 
costs pursuant to Rule 1408 given applicant's harassment of 
respondent — Canada Labour Code, R.S.C. 1970, c. L-1, s. 
61.5(9) (as enacted by S.C. 1977-78, c. 27, s. 21), (12) (as 
enacted idem), (13) (as enacted idem) — Federal Court Rules, 
C.R.C., c. 663, R. 1408. 
Constitutional law — Charter of Rights — Freedom of 
expression — Applicant unjustly dismissing respondent — 
Adjudicator ordering future inquiries concerning respondent's 
employment be answered only by letter of recommendation 
stating specified facts — Order not infringing right to freedom 
of opinion and expression guaranteed by s. 2(b) of Charter — 
S. 2 subject to "such reasonable limits prescribed by law as 
can be demonstrably justified in a free and democratic socie
ty" pursuant to s. 1 — Since order authorized by s. 61.5(9)(c) 
of Code, limits "prescribed by law" — Limits demonstrably 
justified as evidence disclosing harassment — Canadian 
Charter of Rights and Freedoms, being Part I of the Constitu
tion Act, 1982, Schedule B, Canada Act 1982, 1982, c. 11 
(U.K.), ss. 1, 2(b) — Canada Labour Code, R.S.C. 1970, c. 
L-1, s. 61.5(9) (as enacted by S.C. 1977-78, c. 27, s. 21), (12) 
(as enacted idem), (13) (as enacted idem). 
An application was brought to set aside an Adjudicator's 
decision. The Adjudicator found that the respondent had been 
unjustly dismissed and ordered the applicant to give the 
respondent a letter of recommendation containing five explicit 
statements and ordering it to answer future inquiries about the 
respondent's employment exclusively by delivering a copy of the 
letter. The Adjudicator also retained jurisdiction to decide any 
dispute relating to the implementation of his order. The appli
cant submitted that the Adjudicator had no authority under 
subsection 61.5(9) of the Canada Labour Code to make such 
orders. The applicant argued that the presence of "like" in the 
phrase "any other like thing" in paragraph 61.5(9)(c) limited 
the Adjudicator's powers to ordering relief similar to payment 
of compensation or reinstatement. It further argued that the 
limitation on its response to inquiries infringes its constitution
ally guaranteed right to freedom of expression. 
Held (Marceau J. dissenting), the application is dismissed 
with costs. 
Per Mahoney J.: The purported retention of jurisdiction 
served no useful purpose since the Federal Court of Appeal 
held in Huneault v. General [sic] Mortgage and Housing 
Corporation that such a retention of jurisdiction does not give 
an adjudicator power to reconsider, withdraw or change an 
order made. Its inclusion, even where superfluous does not 
vitiate the decision. Subsection 61.5(9) of the Code gives an 
adjudicator power to order an employer to pay compensation, 
to reinstate the person, and to do "any other like thing ... in 
order to remedy or counteract any consequence of the dismis
sal." The French version does not contain a counterpart of the 
word "like". The word "like" is not intended to restrict narrow
ly the remedial action authorized to something like monetary 
compensation or reinstatement. Paragraph 61.5(9)(c) simply 
expresses the ejusdem generis rule of construction. 
The Supreme Court of Canada decision in National Bank of 
Canada v. Retail Clerks' International Union is distinguishable 
because there the employer was required to express opinions 
which it did not hold. The ordering of provision. of a totally 
factual letter of recommendation and foreclosing the undermin
ing of its effect which, in the circumstances disclosed by the 
evidence was patently foreseeable, seems to be an equitable 
remedial requirement. It is not punitive. It is authorized by 
paragraph 61.5(9)(c). 
The constitutionally guaranteed right of freedom of expres
sion and opinion in paragraph 2(b) of the Charter is subject to 
the qualification of section 1. Section 1 is not merely introduc
tory, but is a substantive provision. 
The limitations on the applicant's freedoms are prescribed by 
law since the order was authorized under paragraph 61.5(9)(c). 
On the evidence, they were demonstrably justified in a free and 
democratic society. 
This application was part of the applicant's harassment of 
the respondent. The Court therefore exercised its discretion 
under Rule 1408 to dismiss the application with costs. 
Per Urie J.: Since it is difficult to ascertain a genus in the 
words "any other like thing" common to the dissimilar reme
dies provided for in paragraphs 61.5(9)(a) and (b), it is prefer
able not to apply the ejusdem generis rule of construction. The 
presence of "like" in paragraph 61.5(9)(c) demonstrates the 
intent of the paragraph to enlarge the traditional and obvious 
remedies for unjust dismissal. 
Per Marceau J. (dissenting): The application should be 
allowed. The Adjudicator had no power to retain jurisdiction. 
When a decision is rendered with nothing to be completed, the 
adjudicator is functus officio. However, the inclusion in the 
decision of a stipulation to which no legal effect attaches 
cannot of itself vitiate the decision. 
Some of the remedies ordered are positive in that they consist 
of the doing of something (a letter of recommendation stating 
certain facts will be given to the respondent and thereafter 
copies thereof will be sent or delivered to inquirers) whereas 
others are negative in that they preclude the doing of something 
(the letter of recommendation will not contain any other state
ments than those prescribed and in the future no information 
other than that contained in the letter will be given). The 
"positive remedies" were available to the Adjudicator, but the 
"negative" ones were not, because they were not authorized by 
the statute and because they infringed the applicant's constitu
tionally guaranteed right to freedom of opinion and expression. 
The word "like" does not restrict narrowly the remedial 
action. It is even difficult to apply the ejusdem generis rule of 
construction since there is no common category into which 
"compensation" and "reinstatement" fall with respect to the 
nature of remedies. However, the words used thereafter, "to 
remedy or counteract any consequence of the dismissal" indi
cate that the remedial measures must be aimed at compensat
ing for the unjust dismissal. 
The letter was clearly aimed at remedying the damaging 
effect of unjust dismissal, but the negative remedies were aimed 
at the possible animosity of the applicant and its management 
towards the respondent. 
The limits imposed by section 1 of the Charter are to be 
determined by rules of general application, hence the phrase 
"prescribed by law" and the reference to the characteristics of 
a free and democratic society. 
Even if section 1 was meant to apply in individual cases 
based on their particular circumstances, it cannot validate the 
breach of freedom of opinion and expression in this case. It 
cannot even be justifiable in a free and democratic society to 
prohibit an employer from expressing in the future any opinion, 
even in private, about a former employee on the ground that 
there is some reason to believe that the employer may express a 
dishonest or biased opinion because of resentment towards the 
former employee. 
CASES JUDICIALLY CONSIDERED 
APPLIED: 
Huneault v. General [sic] Mortgage and Housing Corpo
ration (1982), 41 N.R. 214 (F.C.A.). 
DISTINGUISHED: 
National Bank of Canada v. Retail Clerks' International 
Union et al., [1984] 1 S.C.R. 269. 
CONSIDERED: 
Hunter et al. v. Southam Inc., [1984] 2 S.C.R. 145; 55 
N.R. 241. 
REFERRED TO: 
Minister of National Revenue v. Kruger Inc., [1984] 2 
F.C. 535; 55 N.R. 255 (C.A.); R. v. Big M. Drug Mart 
Ltd. (1983), 7 C.R.R. 92 (Alta. C.A.); Re Reynolds and 
Attorney General of British Columbia (1984), 11 D.L.R. 
(4th) 380 (B.C.C.A.); Rauca v. R. et al. (1983), 4 
C.R.R. 42 (Ont. C.A.); Attorney General of Quebec v. 
Quebec Association of Protestant School Boards et al., 
[1984] 2 S.C.R. 66. 
COUNSEL: 
Brian A. Grosman, Q.C. for applicant. 
Morris Cooper for respondent. 
SOLICITORS: 
Brian A. Grosman, Q.C., Toronto, for 
applicant. 
Morris Cooper, Toronto, for respondent. 
The following are the reasons for judgment 
rendered in English by 
URIE J.: I have had the advantage of reading 
the draft reasons for judgment prepared by my 
brothers Mahoney J. and Marceau J. While Mr. 
Justice Marceau's reasons are persuasive, with 
deference, I find myself to be more in accord with 
those of Mr. Justice Mahoney. I have only one 
minor qualification in respect of that endorsement 
and that relates to his view that paragraph (c) of 
subsection 61.5(9) of the Canada Labour Code 
[R.S.C. 1970, c. L-1 (as enacted by S.C. 1977-78, 
c. 27, s. 21)] simply expresses "the generally appli
cable ejusdem generis rule of construction". I am 
not sure that that rule applies in the context of the 
subsection so that I would prefer not to rely upon 
it in reaching my conclusion. The difficulty I have 
in applying the rule here is in ascertaining a genus 
in the words "any other like thing" common to the 
quite dissimilar remedies provided for in the 
preceding paragraphs (a) and (b). However, 
whether or not the rule applies, there is, in my 
view, no doubt as to the construction to be given 
the subsection. 
The presence of the word "like" in paragraph 
(c) does not, as I see it, restrict the nature of the 
remedies which may be granted, to one or more 
which must be akin to those permitted by para
graphs (a) and (b), and which, as I have said, do 
not have a common genus. Rather, its presence 
demonstrates the intent of the paragraph, i.e. to 
enlarge the traditional and obvious remedies which 
should be available when an employee has been 
wrongfully dismissed. 
The intent of the subsection as a whole is to 
provide authority for granting remedies which, as 
nearly as an award may do, will make whole an 
employee who has been wrongfully treated by his 
employer. That is accomplished in part in the 
manner contemplated by the powers granted by 
either paragraphs (a) or (b), or both. The latter 
permits the award of a remedy to a dismissed 
employee which was not available in common law. 
The same is true of paragraph (c). It is an author
ity which, in my opinion, ought not to be narrowly 
construed. To make whole a person who has been 
wronged depends upon the extent of the injury 
inflicted as disclosed by the circumstances of each 
case. On the facts of this case, the Adjudicator felt 
it appropriate to utilize the authority to do what 
was equitable, in his view, to ensure that the 
aggrieved employee did not again become the 
victim of what appears to have been a vendetta 
against him. For the other reasons given by 
Mahoney J. I am of the opinion that the wording 
of paragraph (c) is sufficiently broad to permit the 
Adjudicator to make the impugned order and that 
the subsection does not offend the Canadian 
Charter of Rights and Freedoms [being Part I of 
the Constitution Act, 1982, Schedule B, Canada 
Act 1982, 1982, c. 11 (U.K.)]. 
I also agree with the disposition of the applica
tion proposed by Mahoney J. 
* * * 
The following are the reasons for judgment 
rendered in English by 
MAHONEY J.: This section 28 application seeks 
to set aside the decision of Edward B. Joliffe, Q.C., 
an Adjudicator under Part III of the Canada 
Labour Code, who found that the respondent had 
been unjustly dismissed. In my respectful opinion, 
in view of his findings of fact, the Adjudicator was 
fully justified in making the order he did. 
While he did not say it in so many words, the 
Adjudicator was plainly of the view that the 
respondent had been the victim of a set-up, ini
tiated by his employer's general manager, and 
executed by its sales manager. The sales manager 
was the only witness for the applicant. The 
Adjudicator stated: "her evidence must be con
sidered misleading". There is no verbatim record 
of the Adjudicator's hearing. We must accept his 
account of the evidence. Two critical passages 
from his decision follow: 
Notwithstanding suggestions that other salesmen were more 
effective, no figures were produced to prove it. Ms. Stitt 
testified that the company's General Manager, Mr. G. Slaight 
"had been concerned about Davidson's performance. Mr. 
Slaight had complained to me and said I had to do something 
about it. If he failed to make budget, I'd hear about it. If he 
made it, the complaint would be that he could do more." 
The conclusion is inescapable that unsatisfactory perform
ance as a salesman of radio time has not been proved. If a 
salesman is "unsatisfactory" when he doubles his sales in only 
two years, thereby increasing commission earnings from 
$31,428.92 to $62,171.95, it is difficult to imagine just what 
would constitute satisfactory sales performance. 
The Adjudicator found the other grounds 
advanced to justify the dismissal equally fatuous 
on the evidence. 
The Adjudicator decided against ordering rein
statement. He awarded compensation of 
$46,628.96 with interest and costs. The only issues 
with which we need deal, and which counsel for 
the respondent was called upon to argue, are those 
arising out of the following: 
Under the power given me by paragraph (c) in subsection (9) 
of Section 61.5, I further order: 
That the employer give the complainant a letter of recom
mendation, with a copy to this adjudicator, certifying that; 
(1) Mr. Ron Davidson was employed by Station Q 107 from 
June, 1980 to January 20, 1984, as a radio time salesman; 
(2) That his sales "budget" or quota for 1981 was $248,000 
of which he achieved 97.3 per cent; 
(3) That his sales "budget" or quota for 1982 was $343,500 
of which he achieved 100.3 per cent; 
(4) That his sales "budget" or quota for 1983 was $402,200 
of which he achieved 114.2 per cent; 
(5) That following termination in January, 1984, an 
adjudicator (appointed by the Minister of Labour) after 
hearing the evidence and representations of both parties, held 
that the termination had been an unjust dismissal. 
I further order that any communication to Q107, its manage
ment or staff, whether received by letter, telephone or other
wise, from any person or company inquiring about Mr. Ron 
Davidson's employment at Q107 shall be answered exclusively 
by sending or delivering a copy of the said letter of 
recommendation. 
I retain jurisdiction to decide any dispute relating to the 
implementation of the above orders if either party requests me 
to do so. 
The purported retention of jurisdiction seems to 
be quite usual in Adjudicators' decisions. What
ever its intended purpose, it served no useful pur
pose here; the Adjudicator did not purport to act 
on it. As held by this Court in Huneault v. General 
[sic] Mortgage and Housing Corporation (1982), 
41 N.R. 214 (F.C.A.), such a retention of jurisdic
tion does not give an adjudicator power to recon
sider, withdraw or change an order made. I would 
say no more of it than that, in my opinion, its 
inclusion, even where superfluous, does not of itself 
vitiate the decision. 
The applicant argues that the Adjudicator had 
no authority to order it to give the letter nor to 
limit its answer to the provision of a copy of the 
letter. It further argues that the limitation on its 
response to inquiries infringes its constitutionally 
guaranteed right to freedom of expression. 
The Code provides: 
61.5... 
(9) Where an adjudicator decides pursuant to subsection (8) 
that a person has been unjustly dismissed, he may, by order, 
require the employer who dismissed him to 
(a) pay the person compensation not exceeding the amount 
of money that is equivalent to the remuneration that would, 
but for the dismissal, have been paid by the employer to the 
person; 
(b) reinstate the person in his employ; and 
(c) do any other like thing that it is equitable to require the 
employer to do in order to remedy or counteract any conse
quence of the dismissal. 
The French version of paragraph (c) provides: 
c) de faire toute autre chose qu'il juge équitable d'ordonner 
afin de contrebalancer les effets du congédiement ou d'y 
remédier. 
The French version contains no counterpart of 
the word "like" which appears in the English 
version. In my opinion, the word "like" in the 
English version is not intended to restrict narrowly 
the remedial action authorized to something like 
monetary compensation or reinstatement. Para
graph (a) imposes a ceiling on monetary compen
sation which renders potentially nonsensical au
thority to award any other remedy like it. 
Reinstatement is reinstatement. It entails reem-
ployment by the same employer. There seems little 
scope for anything else very much like it. I take 
paragraph (c) as simply expressing the generally 
applicable ejusdem generis rule of construction. 
The intent of subsection 61.5(9) is to empower the 
adjudicator, as near as may be, to put the wronged 
employee in the position of not suffering an 
employment related disadvantage as a result of his 
unjustified dismissal. 
I am, of course, aware of the decision in Nation
al Bank of Canada v. Retail Clerks' International 
Union et al., [ 1984] 1 S.C.R. 269. The letter 
ordered in that case required the employer to 
express, or at least imply, opinions which it did not 
necessarily hold. Here, the applicant has simply 
been ordered to tell the truth. The letter sets out 
bald facts that are neither misleading nor disputed. 
The ordering of provision of a totally factual 
letter of recommendation and foreclosing the 
undermining of its effect which, in the circum
stances disclosed by the evidence, was patently 
foreseeable, seems to me to be an equitable 
remedial requirement. It is not punitive. It is 
appropriate redress to the wronged employee with
out, in any way, injuring the employer. In my 
view, the order was authorized by paragraph 
61.5(9)(c). 
The order undoubtedly imposes limitations on 
the applicant's constitutionally guaranteed right of 
freedom of expression and opinion both in dictat
ing what it must say in the letter and prohibiting it 
from saying more. That fundamental freedom, 
guaranteed by paragraph 2(b) of the Canadian 
Charter of Rights and Freedoms, is subject only to 
the qualification of section 1. 
1. The Canadian Charter of Rights and Freedoms guaran
tees the rights and freedoms set out in it subject only to such 
reasonable limits prescribed by law as can be demonstrably 
justified in a free and democratic society. 
2. Everyone has the following fundamental freedoms: 
(b) freedom of thought, belief, opinion and expression, 
including freedom of the press and other media of 
communication; 
With all due respect to contrary views, I do not 
accept section 1 of the Charter as merely introduc
tory in the sense of it being something of a recital 
or preamble. I think it is a substantive provision. It 
appears to have been so regarded by the majority 
of this Court in Minister of National Revenue v. 
Kruger Inc., [1984] 2 F.C. 535; 55 N.R. 255 
(C.A.), and it has certainly been so construed by a 
number of provincial appellate courts: e.g. R. v. 
Big M. Drug Mart Ltd. ( 1983), 7 C.R.R. 92 (Alta. 
C.A.), at pages 112 ff.; Re Reynolds and Attorney 
General of British Columbia (1984), 11 D.L.R. 
(4th) 380 (B.C.C.A.) and Rauca v. R. et al. 
(1983), 4 C.R.R. 42 (Ont. C.A.), at pages 58 ff. 
While the Supreme Court of Canada appears not 
yet to have dealt with the question in a definitive 
way, its dicta indicate agreement with that 
approach, e.g. Attorney General of Quebec v. 
Quebec Association of Protestant School Boards 
et al., [ 1984] 2 S.C.R. 66, at pages 77-78; 10 
D.L.R. (4th) 321, at page 330. In Hunter et al. v. 
Southam Inc., [1984] 2 S.C.R. 145, at page 169; 
55 N.R. 241, at page 254, Dickson J., as he then 
was, delivering the judgment of the court, said: 
The phrase "demonstrably justified" puts the onus of justify
ing a limitation on a right or freedom set out in the Charter on 
the party seeking to limit. 
I fail to see how any but a substantive provision 
can be construed as imposing a legal onus. 
The order being one the Adjudicator was 
authorized, under paragraph 61.5(9)(c), to make, 
the limitations in issue are prescribed by law. On 
the evidence as recorded by the Adjudicator, they 
were demonstrably justified in a free and demo
cratic society. 
Rule 1408 [Federal Court Rules, C.R.C., c. 
663] provides: 
Rule 1408. No costs shall be payable by any party to an 
application to another unless the Court, in its discretion, for 
special reason, so orders. 
In my opinion, the bringing of this application was 
part and parcel of the applicant's systematic 
harassment of the respondent. 
I would dismiss this application with costs. 
* * * 
The following are the reasons for judgment 
rendered in English by 
MARCEAU J. (dissenting): I have no difficulty 
in adopting most of the views expressed by my 
brother Mahoney J. in his reasons for judgment. 
Indeed, I see absolutely no merit in the applicant's 
contention that the Adjudicator based his decision 
on erroneous findings of fact made without regard 
for the material before him: the attempt of the 
employer to invoke unsatisfactory performance on 
the part of its former employee had clearly failed 
and the conclusion that the dismissal was unjust 
was fully justified. However, I am, unfortunately, 
unable to share Mr. Justice Mahoney's opinion as 
to the legitimacy of all of the orders made by the 
Adjudicator as a result of his finding that the 
dismissal was unjustified and I must, as a conse
quence, respectfully dissociate myself from his 
conclusion that this application for review should 
simply be dismissed. 
The problem of course is with respect to those 
orders made by the Adjudicator in addition to his 
award of $46,628.96 compensation. The relevant 
paragraphs of the decision are again here repro
duced for convenience: 
Under the power given me by paragraph (c) in subsection (9) 
of Section 61.5, I further order: 
That the employer give the complainant a letter of recom
mendation, with a copy to this adjudicator, certifying that; 
(1) Mr. Ron Davidson was employed by Station Q107 from 
June, 1980 to January 20, 1984, as a radio time salesman; 
(2) That his sales "budget" or quota for 1981 was $248,000 
of which he achieved 97.3 per cent; 
(3) That his sales "budget" or quota for 1982 was $343,500 
of which he achieved 100.3 per cent; 
(4) That his sales "budget" or quota for 1983 was $402,200 
of which he achieved 114.2 per cent; 
(5) That following termination in January, 1984, an 
adjudicator (appointed by the Minister of Labour) after 
hearing the evidence and representations of both parties, held 
that the termination had been an unjust dismissal. 
I further order that any communication to Q107, its manage
ment or staff, whether received by letter, telephone or other
wise, from any person or company inquiring about Mr. Ron 
Davidson's employment at Q107 shall be answered exclusively 
by sending or delivering a copy of the said letter of 
recommendation. 
I retain jurisdiction to decide any dispute relating to the 
implementation of the above orders if either party requests me 
to do so. 
There is no need to insist on the inappropriate-
ness of the last paragraph of the decision. The 
Adjudicator had no power to retain jurisdiction to 
decide disputes relating to the implementation of 
his orders. The implementation of an order made 
under subsection (9) of section 61.5 of the Canada 
Labour Code is dealt with by subsections (12) and 
(13) of the section, which provide for the filing, 
registration and enforcement of the order in this 
Court.' When the adjudicator has not seen fit to 
spell out all the constituent elements of his deci-
1 These subsections read as follows: 
61.5... 
(12) Any person affected by an order of an adjudicator 
under subsection (9), or the Minister on the request of any 
such person, may, after fourteen days from the date on which 
the order is made, or the date provided in it for compliance, 
whichever is the later date, file in the Federal Court of 
Canada a copy of the order, exclusive of the reasons therefor. 
(13) On filing in the Federal Court of Canada under 
subsection (12), an order of an adjudicator shall be regis
tered in the Court and, when registered, has the same force 
and effect, and all proceedings may be taken thereon, as if 
the order were a judgment obtained in that Court. 
sion, for example, when the calculation of the 
amount of a reward on a determined basis has 
been left to be made, it may be correct for him to 
say (as he often does apparently) that he wishes to 
be seized of any dispute relating to the exact 
substance of the "missing elements". But the per
fecting of the decision is then involved, not its 
implementation, and the purported retention of 
jurisdiction merely indicates that the decision will 
not be final and definitive until missing elements 
are established. When a decision is rendered with 
nothing to be completed, as here, there is, in my 
mind, no doubt that the adjudicator is functus 
officio: any further action would be entirely with
out authority. It remains nevertheless, as pointed 
out by my brother, that the inclusion in the deci
sion of such a stipulation to which no legal effect 
does attach cannot of itself vitiate the decision. 
The concern is with regard to the mandatory 
injunctions contained in the other provisions which 
are meant to be immediately enforceable. The 
applicant is required to give his former employee 
forthwith a "letter of recommendation" containing 
five precise statements and its management and 
staff are ordered to answer any future inquiry 
about the respondent's employment at the radio 
station by delivering a copy of said letter and by 
that "exclusively". The issue is obvious enough: 
had the Adjudicator authority to make them? I 
respectfully disagree with the view that he had. 
The remedies devised by the Adjudicator in his 
orders are of two types: some are positive in that 
they consist in the doing of something (a letter of 
recommendation stating certain facts will be forth
with given to the respondent and thereafter copies 
thereof will be sent or delivered to inquirers); the 
others are negative in that they preclude the doing 
of something (the letter of recommendation will 
not contain any other statements than those pre
scribed and in the future no information other 
than that contained in the letter will be given). In 
my view, the "positive remedies" were available to 
the Adjudicator but the "negative" ones were not, 
firstly because they were not authorized by the 
statute and, secondly, because in any event, they 
could not be imposed without infringing the appli
cant's constitutionally guaranteed rights to free
dom of opinion and expression. 
1. The powers given to the adjudicator who has 
come to the conclusion that a complainant has 
been unjustly dismissed by his employer are 
defined in subsection (9) of section 61.5 of the 
Canada Labor Code in the following terms: 
61.5.. . 
(9) Where an adjudicator decides pursuant to subsection (8) 
that a person has been unjustly dismissed, he may, by order, 
require the employer who dismissed him to 
(a) pay the person compensation not exceeding the amount 
of money that is equivalent to the remuneration that would, 
but for the dismissal, have been paid by the employer to the 
person; 
(b) reinstate the person in his employ; and 
(c) do any other like thing that it is equitable to require the 
employer to do in order to remedy or counteract any conse
quence of the dismissal. 
The argument advanced in support of the con
tention that the Adjudicator had no authority to 
require the writing of the letter was mostly based 
on the presence of the word "like" in the phrase 
"any other like thing" in paragraph (c). It was 
said that the word effectively restricted the scope 
of the Adjudicator's jurisdiction, limiting his 
powers to ordering things similar to payment of 
money compensation or reinstatement. The argu
ment is unconvincing. I agree with Mr. Justice 
Mahoney that the word "like", which, as noted by 
him, has no counterpart in the French version, 2 
does not appear to have been used to restrict 
narrowly the remedial action to which an unjust 
dismissal could give rise under the Code. It could 
be, as suggested, a sort of reinforcement of the 
ejusdem generis rule of construction, but even that 
rule would be difficult to apply, since there seems 
to be no common category into which the words 
2 Paragraph c), in the French version, reads thus: 
61.5(9)... 
c) de faire toute autre chose qu'il juge équitable d'ordon-
ner afin de contrebalancer les effects du congédiement ou 
d'y remédier. 
"compensation" and "reinstatement" would fall 
with respect to the nature of the remedies (see 
E. A. Driedger, Construction of Statutes, second 
edition, pages 111 et seq.). So, the presence of the 
word "like" should not be taken as restricting in 
any particular way the remedial action contem
plated by the provision but there are words used 
thereafter, namely "to remedy or counteract any 
consequence of the dismissal" which cannot be 
understood otherwise. The whole of the provision 
emphasizes a clear and unequivocal limit to the 
powers of the adjudicator, a limit which was 
already dictated by common sense in view of the 
role assigned to him but which Parliament has 
chosen to emphasize: the measures an adjudicator 
may impose must be strictly aimed at compensat
ing for the unjust dismissal, at counterbalancing or 
making up for it. 
There seems to be no doubt that the "positive 
remedies" devised by the Adjudicator remained, in 
that respect, within the Adjudicator's authority. 
The letter which was setting out purely established 
facts was clearly aimed at "remedying" or "coun-
teracting" the damaging effect that a dismissal 
allegedly based on poor performance could have on 
the respondent's chances of adequate reemploy-
ment and, for that matter, on his whole career. 
But, I do not think that the same can be said of the 
"negative remedies". The imposing of a gag on the 
applicant and its staff was not, as I see it, aimed at 
remedying the effect of the dismissal itself. The 
Adjudicator had obviously in view the possible 
animosity of the applicant and its management 
towards the respondent, their possible resentment 
following the filing of the complaint or even their 
dislike for the man, all of which could give rise to 
bias if not simple bad faith when inquiries about 
him would be made. In my respectful opinion the 
Adjudicator, however well intentioned he may 
have been, was not entitled to try to counterbal
ance the effects on the respondent of such possible 
evils, not to mention that he was acting on assump
tions that were in no way related to his inquiry and 
determination. The negative measures contained in 
the order were, in my view, completely outside the 
purview of the statute. 
2. Even if such measures could be said to be 
theoretically falling within the boundaries of the 
authority conferred on the Adjudicator by the 
Code, I think that, in any event, they could not be 
resorted to because they constituted a direct and 
prohibited infringement upon the freedom of 
thought, belief, opinion and expression of the 
applicant, its management and staff constitutional
ly guaranteed by paragraph 2(b) of the Canadian 
Charter of Rights and Freedoms. It is said that 
the fundamental freedom guaranteed by this para
graph 2(b) of the Charter is subject to the qualifi
cation of section 1, that is to say subject "to such 
reasonable limits prescribed by law as can be 
demonstrably justified in a free and democratic 
society", and that the limitations imposed by the 
Adjudicator on the freedom of opinion and expres
sion of the applicant in this case were, on the 
evidence recorded by him, "demonstrably justified 
in a free and democratic society". 
I have had occasion in the past to express some 
doubts as to the exact purpose and meaning to be 
attributed to section 1 of the Charter and more 
precisely as to whether the provision contained 
therein was meant to be given application on a 
case-to-case basis, each one being considered 
according to its particular context and with due 
regard to its distinctive features. It seemed to me 
that the control to be imposed was on the legisla
tive function of the State, and that the limits 
contemplated were limits expressly determined by 
rules of general application, hence the phrase "pre-
scribed by law" and the reference to the character
istics of a free and democratic society. If such was 
the case, the justification required had to be that 
of the rules themselves as adopted and made appli
cable, not of their application in a particular 
instance (this incidentally appears to be the view 
taken by Peter W. Hogg in Canada Act 1982 
Annotated, pages 10 and 11). I do not think the 
Supreme Court has had occasion to address the 
question squarely and as a result, my doubts have 
not been put to rest yet. But, in any event, even if I 
were to leave aside these doubts and accept that 
section 1 of the Charter was meant to have a role 
to play in validating, in individual cases, on the 
basis of their particular circumstances, a breach of 
a right or freedom secured by the following sec
tions of the Charter, I would, nevertheless, be 
forced to respectfully disagree that it could have 
been so in this case. I simply cannot convince 
myself that in a free and democratic society it may 
ever be justifiable to prohibit the one-time employ
er of a man from expressing in the future even in 
private (assuming the enforceability of such an 
order in practice), any opinion about that man and 
his qualifications as employee, on the sole ground 
that there is some reason to believe that this 
employer may be resentful towards his former 
employee and therefore may express an opinion 
that could be biased or dishonest. 
Those are the reasons why I think that the 
Adjudicator could not prohibit the applicant from 
expressing any opinion about the respondent in 
addition to delivering the letter of recommenda
tion. By resorting to such a remedy the Adjudica
tor was acting without statutory authority and in 
contravention of the Charter. His decision cannot 
be allowed to stand as it is. I would therefore allow 
the application, set the decision aside and refer the 
matter back to the Adjudicator for reconsideration 
of the remedies he should impose within his au
thority to counteract the unjust dismissal of the 
respondent. 
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