What is the severe and/or severe criterion for assessing performance, productivity or and profitability?

Canada (Federal), Canada

The following excerpt is from Z. H. v Minister of Employment and Social Development, 2015 SSTAD 759 (CanLII):

Counsel further submits that the Applicant “does not have the ability to fulfill employment capacity on the basis of his performance, productivity or and profitability”, and submits that the severe criterion must be assessed in a real world context, as set out in Villani v. Canada (Attorney General), 2001 FCA 248.

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