What is the test for reckless dismissal, flagrant misconduct and/or deliberate misconduct?

There is no doubt on the evidence that the conduct of the defendant was reckless in dismissing the plaintiff without just cause, but I cannot find it was flagrant and deliberate misconduct, even though they did attempt to avoid their obligations under the Employment Standards Act, their actions have to be regarded in the light of their perceived catastrophic conditions and the general financial climate of that period. As McIntyre J. said in Vorvis v. Insurance Corp. of British Columbia, in 1989 [1989 CanLII 93 (SCC), 25 C.C.E.L. 81 (S.C.C.) at p. 102]: In my view… in any case where such an award [punitive damages] is made the conduct must be extreme in its nature and such that by any reasonable standard it is deserving of full condemnation and punishment.