HomeMy WebLinkAboutP-2023-01791.Nagra.24-09-13 Decision
Public Service
Grievance Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Commission des
griefs de la fonction
publique
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
PSGB# P-2023-01791
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Nagra Complainant
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The Crown in Right of Ontario
(Ministry of Labour, Immigration, Training and Skills
Development) Employer
BEFORE Jayashree Sengupta Vice Chair
FOR THE
COMPLAINANT
Harjinder Nagra
FOR THE EMPLOYER Benjamin Parry
Treasury Board Secretariat
Legal Services Branch
Counsel
CONFERENCE CALL
SUBMISSIONS
November 21, 2023
December 19, 2023, January 16 and
February 13, 2024
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Decision
[1] This decision deals with the Employer’s preliminary objection to the Board
considering this application on the basis that this is a complaint about a dismissal
without cause in which the Complainant seeks, among other remedies,
reinstatement and the Board lacks jurisdiction to either hear it or to order the
relief sought.
[2] The Employer argues that as the Complainant, Mr. Nagra, was dismissed without
cause from his employment with the Employer pursuant to s.38(1) of the Public
Service of Ontario Act, 2006 (the “PSOA”), a matter that s.4(2) of Ontario
Regulation 378/07 (the “Regulation”) states cannot be the subject of a grievance
before the Board, the complaint should be dismissed without a hearing.
[3] The Complainant’s position is that his application is about more than his
dismissal. He says he did not have an opportunity to grieve the leave of absence
from work or investigation that preceded his dismissal. He asserts that, in
addition to his dismissal, the complaint is also about the leave of absence, an
improper and unfair investigation into his conduct, bad faith treatment,
discrimination, reprisal, breach of confidentiality, harassment, bullying and abuse
of power by his superiors, all of which culminated in his dismissal.
Background
[4] The Complainant began his employment with the Ontario Public Service on May
3, 2021. From August 2022, he worked as a Program Manager in the Industrial
Health and Safety Program – York West, part of the Ministry’s Fair, Safe and
Healthy Workplaces Division.
[5] In his Form 1, the Complainant described experiencing incidents of disrespect,
harassment and threats of termination from his immediate supervisor, being
compelled by the supervisor to impose certain disciplinary measures on staff that
reported to him and that his mental health suffered as a result of exposure to
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traumatizing images and interactions with grieving family members. He states
this happened between August 2022 to April 2023.
[6] The Complainant was placed on a leave of absence with pay on May 1, 2023,
pending completion of a workplace investigation into his conduct. Although the
leave of absence was to last 20 days, it was extended several times. The
ongoing absence from his workplace caused him significant distress and he
reported that it had a further negative impact on his mental health. On August
28, 2023, the Complainant’s employment was terminated.
[7] On September 7, 2023, the Complainant sent the Employer a Notice of Proposal
indicating that he intended to file a complaint concerning his “dismissal without
cause”. He went on to state that his employment was “erroneously or improperly”
terminated, that prior to the termination, he had been placed on an undue and
lengthy 4-month leave of absence pending completion of an investigation into
complaints about his conduct and that he was denied an opportunity to
meaningfully participate in that investigation.
[8] On September 20, 2023, the Employer replied to the Complainant’s Notice of
Proposal, reiterating that he had been dismissed without cause by giving
compensation in lieu of reasonable notice, pursuant to s.38(1) of the PSOA, and
confirming that the Employer did not intend to reverse the decision.
[9] The complaint to the PSGB filed on October 1, 2023, outlined the Complainant’s
grievances and sought, in addition to reinstatement, a number of additional
remedies including relocation costs, salary and benefit continuance, monetary
damages and some non-monetary remedies.
The Parties’ Positions
[10] The Employer argued that the Board must have statutory authority to adjudicate
a complaint as it has no inherent jurisdiction, relying on Burt v. Ontario (MCSCS),
2011 CanLII 2330 (ON PSGB) (O’Neil). It submitted that in the present
application, the Board lacks jurisdiction as the complaint concerns the
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Complainant’s dismissal without cause, pursuant to s.38(1) of the PSOA, or
matters relating to the dismissal.
[11] The Employer submitted that the Regulation contains specific language in
paragraph 3 of s. 4(2) that “a dismissal without cause under s.38(1) of the PSOA
or a matter relating to such a dismissal” cannot be the subject of a grievance
before the Board.
[12] The Employer also asserted that the Board lacks authority to order the requested
remedy of reinstatement, pointing to s. 38(2) and s. 40 of the PSOA as support
for that proposition. It argued that the Board has long held that it will not take
jurisdiction over a matter if it does not have remedial authority, citing Hasted v.
Ontario (Community Safety and Social Services), 2016 CanLII 7473 (ON PSGB)
(Nairn), Saunders et al v. Ontario (Attorney General), 2015 CanLII 8601 (ON
PSGB) (O’Neill), Tighe v. Ontario (Solicitor General), 2020 CanLII 45594 (ON
PSGB) (Devins), and Ryan v. Ontario (Community and Social Services) 2015
CanLII 8599 (ON PSGB) (O’Neil).
[13] Finally, the Employer also identified the following additional objections that it
reserved the right to raise in the event that its initial objection was denied:
a. The complaint was filed during the period of dispute
resolution, contrary to the process set out in the Regulation;
b. The Complainant cannot file an application regarding
working conditions as he was not a public servant at the time
that he gave the Employer the Notice of Proposal; and
c. Issues not identified in the Notice of Proposal but included
in the Form 1 filed with the Board are not properly before the
Board.
[14] In his response to the Employer’s preliminary objection, the Complainant argued
that his application concerns more than the termination of his employment.
Despite objecting to the Employer’s submission that it reserved the right to raise
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additional objections to the Board’s jurisdiction, the Complainant addressed
some of those possible arguments in his response. He also indicated that he
would file additional submissions if those objections were subsequently raised.
[15] The Complainant asserted that even if the Board agreed with the Employer’s
position that it lacks jurisdiction to consider his dismissal without cause, it should
not dismiss his application as he could not raise his complaints about events that
preceded the termination of his employment at the time they occurred.
[16] He characterized those complaints as falling within the categories of workplace
discipline and working terms and conditions of employment (sections 3 and 4 of
the Regulation).
[17] The Complainant’s response did not dispute that those complaints were not
raised at the time that the events occurred, other than to say that he was unable
to do so. He did not speak to the fact that some of the issues did not form part
of his Notice of Proposal. Nor did he address the fact that he was not a public
servant as defined in the Regulation at the time that he filed his Notice of
Proposal. Finally, he did not address the argument that he filed his Form 1 during
the dispute resolution period.
ANALYSIS AND DECISION
Relevant Legislative Provisions
[18] Sections 2 and 32 of the PSOA define who is considered a public servant.
Section 2 reads as follows:
2 For the purposes of this Act, the following are public servants:
1. Every person employed under Part III.
2. The Secretary of the Cabinet.
3. Every deputy minister.
4. Every employee of a public body.
5. Every person appointed by the Lieutenant Governor of a
minister to a public body.
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Section 32 speaks to appointment by the Public Service Commission to
employment by the Crown to work in a Commission public body.
[19] Section 22 of the PSOA sets out the powers, duties and functions of the PSGB:
22 The Public Service Grievance Board may exercise the powers and shall
perform the duties and functions assigned to it under this or any other Act.
[20] Section 38(1) and (2) and section 40 of the PSOA speak to dismissal without
cause and the effect of dismissal:
38(1) The Public Service Commission may without cause dismiss a public
servant appointed by it who is employed in a class of position that is
prescribed under clause 55(1)(b) by giving the public servant reasonable
notice or by giving the public servant compensation in lieu of notice.
38(2) An order to reinstate a public servant who is dismissed under
subsection (1) shall not be made by any court, tribunal or other arbitrator.
40 When the dismissal of a public servant takes effect, he or she ceases to
be employed by the Crown.
[21] Section 5(1) of the Regulation addresses the question of eligibility generally while
subsections (2) and (3) set out exceptions. Section 5(1) is reproduced below:
5(1) Subject to subsections (2) and (3), a public servant or other person is
eligible to file a complaint if he or she was appointed by the Public Service
Commission under subsection 32(1) or (2) of the Act to employment by the
Crown.
[22] Section 3(1) of the Regulation concerns complaints about a disciplinary measure:
3(1) A public servant who is aggrieved by the imposition of a disciplinary
measure under section 34 of the Act, other than dismissal for cause, may file
a complaint about the disciplinary measure with the Public Service Grievance
Board,
(a) if the public servant is eligible under section 5 to file such a complaint;
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(b) if the public servant gives notice in accordance with section 8 of his or
her proposal to file the complaint; and
(a) if the public servant complies with the filing
requirements set out in section 10
[23] Section 4(1) of the Regulation provides the following about the filing of a
complaint about a working condition or a term of employment:
4(1) Subject to subsection (2), a public servant who is aggrieved about a
condition or about a term of his or her employment may file a complaint about
the working condition or the term of employment with the Public Service
Grievance Board,
(a) If the public servant is eligible under sections 5 and 7
to file such a complaint;
(b) If the public servant gives notice in accordance with
section 8 of his or her proposal to file the complaint;
and
(c) If the public servant complies with the filing
requirements set out in section 10.
[24] Section 4(2) sets out the types of matters that are not properly the subject of
complaints under subsection (1) and states, in part, as follows:
4(2) The following matters cannot be the subject of a complaint about a
working condition or about a term of employment:
……
3. A dismissal without cause under subsection 38(1) of the Act or a matter
relating to such a dismissal.
Conclusion
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[25] I find, for the reasons that follow, that the Board does not have jurisdiction to hear
this application.
[26] This Board is a creature of statute, and its jurisdiction is defined by its enabling
legislation. Burt v. Ontario (Community Safety and Correctional Services), 2011
CanLII 23300 (ON PSGB) (O’Neil).
[27] The Regulation clearly states that the Board does not have jurisdiction to
consider a complaint about dismissal without cause under s.38(1) of the PSOA
and matters relating to such dismissals (s.4(2)3 of the Regulation).
[28] There is no dispute that the Complainant was dismissed without cause on August
28, 2023, or that he filed a Notice of Proposal on September 7, 2023.
[29] I find that the content of the Notice of Proposal and the issues raised in it fall
within the category of matters that cannot be the subject of a complaint before
the Board pursuant to s.4(2)3 of the Regulation.
[30] In the Notice of Proposal, the Complainant wrote, in part, that:
I propose to file a complaint concerning my dismissal without cause dated
August 28, 2023, from my position as Program Manager, Industrial Health
and Safety Program – York West.
While I reserve the right to amend or expound on detail in the complaint
proper, in brief, the grounds for my complaint are as follows:
1. My employment was terminated erroneously or improperly
by the Ontario Public Service;
2. Precedent to my termination, I was placed on a leave of
absence of undue length lasting more than 4 months
pending an investigation into complaints about my conduct;
and
3. I was denied an opportunity to participate meaningfully or
at all in the investigation, including, being provided with the
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specific conduct complained of, and/or having the
opportunity to respond substantively to the allegations.
[31] The Complainant went on to describe the impact the dismissal and “protracted
nature of the leave of absence” had on him and his family and expanded on his
concern that he had not been able to properly participate in the investigation into
his conduct.
[32] I find that the focus of the complaint identified in the Notice of Proposal was the
dismissal without cause and the remaining issues identified were matters relating
to the dismissal. I find support for this conclusion in the fact that the dismissal is
framed by the Complainant as the culmination of the problems he says he
experienced, and that among other remedies outlined in his Form 1, he seeks
reinstatement.
[33] Even assuming without finding that the references to the leave of absence and
investigation in the Notice of Proposal do not fall within the category of “matters
relating to the dismissal”, but rather, as the Complainant urges, complaints about
either workplace discipline or working terms and conditions of employment, made
under sections 3 and 4 of the Regulation, the Board would still lack jurisdiction to
continue to hear this application.
[34] To file a complaint under either section 3 or 4, the Regulation requires that the
Complainant be a public servant at the time the Notice of Proposal is sent to the
Employer. He was not. Once his dismissal took effect, under s. 40 of the PSOA,
t he Complainant ceased to be an employee of the Crown.
[35] Other than the dismissal, the Form 1 identified a number of issues such as “bad
faith treatment, discrimination, reprisal, breach of confidentiality, improper/unfair
investigation, harassment, bullying and abuse of power”. These complaints are
either not mentioned or, in the case of the investigation, mentioned in the context
of his dismissal without cause in the Notice of Proposal.
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[36] The issues not referred to at all in the Notice of Proposal are not properly before
the Board. The Regulation requires that an application to the Board be preceded
by a Notice of Proposal. As the Board held in paragraph 9 of Roussel and Ontario
(Ministry of Community Safety and Correctional Services), 2018 CanLII 109224
(ON PSGB) (Nairn):
Prior to filing a complaint with this Board, section 8 of Regulation 378/07
requires a complainant to file a notice of proposal to file a complaint with his
or her Deputy Minister. Apart from time limits in that regard, the purpose of
the notice of proposal is to trigger a dispute resolution process, during which
time the Employer is given an opportunity to respond to the matters intended
to be raised in a subsequent complaint. Thus, the Regulation also stipulates
that the notice of proposal is to set out the reasons for the complaint.
[37] The Complainant’s concerns about “bad faith treatment, discrimination, reprisal,
breach of confidentiality, harassment, bullying and abuse of power” were not
mentioned or included in the Notice of Proposal, which in any event, was not sent
to the Employer while he was a public servant.
[38] Accordingly, the Employer’s jurisdictional objection is granted, and the complaint
is dismissed.
Dated at Toronto, Ontario this 13th day of September 2024.
“Jayashree Sengupta”
Jayashree Sengupta, Vice-Chair