Can an individual employee bring a judicial review of an award made by a union under a collective agreement?

It is trite law that, under the exclusive representation model of collective bargaining, only the union and employers have standing to judicially review labour arbitration awards. This court explained in Misra v. City of Toronto, 2016 ONSC 2246 (Div. Ct.), at para. 56, that there are only three narrow circumstances in which an individual employee can seek judicial review: (1) where the collective agreement expressly confers that right; (2) where the union takes a position adverse in interest to the employee; or (3) where the union’s representation of the employee was so unfair or deficient that the employee should be given the right to pursue judicial review.