Letter of Reference

In Arseneault (Succession de) c. École Sacré-Coeur de Montréal, the Quebec Court of Appeal awarded a dismissed employee $5,000 in damages on account of the defendant employer’s refusal to give her a letter of reference, following dismissal.  The court seems to have implied a term in the contract of employment by way of a double negative: that is, that a refusal to provide a letter of reference must not be contrary to good faith requirements, particularly because a curriculum vitae is an integral component of a person’s reputation.  Query: whether this principle will be picked up in Ontario courts.