By Adam Walji ( July 24, 2026, 2:33 PM EDT) -- The law governing damages arising from the manner of dismissal appeared to be settled nearly two decades ago. In Honda Canada Inc. v. Keays, 2008 SCC 39 (Honda), the Supreme Court of Canada rejected the approach that had developed under Wallace v. United Grain Growers Ltd., (c.o.b. Public Press), [1997] 3 S.C.R. 701 (Wallace), and replaced it with a framework focused on “actual damages.” Under Honda, damages flowing from an employer’s bad faith conduct in the manner of dismissal were to be assessed according to the same principles and in the same way as moral damages rather than through an extension of the employee’s notice period....