In a wrongful dismissal case, is a plaintiff entitled to damages for mental distress?

In Kempling Côté J.A. adds a caution, pp. 191-92: I agree that the rules for damages for mental distress may well be different in wrongful dismissal cases and in other cases. And I agree that such a claim must pass the rule in Hadley v. Baxendale [(1854), 156 E.R. 145] to survive. But whether a plaintiff must pass any other tests (independent cause of action or otherwise) to get such damages, is a more difficult question. I find it hard to discuss that last question in the abstract. It may well depend on the facts or type of case.