What is the state of the law in the context of a collective bargaining agent's grievance?

Canada (Federal), Canada

The following excerpt is from Brunelle v. Canada (Treasury Board), 2003 PSSRB 108 (CanLII):

Counsel for the bargaining agent states, as an alternative position, that these cases could be viewed as disguised discipline. This is the first time this position has been advanced in the context of this grievance and this cannot be done (see Burchill v. Attorney General of Canada, [1981] 1 F.C. 109).

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