How have courts and arbitrators treated sexual harassment in a medical malpractice case?

He also relies on Leach v. Canadian Blood Services, 2001 ABQB 54, [2001] 5 W.W.R. 668 where Justice Coutu said the following at para. 120: ... Many courts and arbitrators have been quick to recognize that harassment with a physical component constitutes a form of sexual assault. While there are some exceptions, the penalty of discharge has been consistently upheld in cases involving inappropriate physical conduct or assault. Where the harassment takes the form of verbal comments, innuendoes, jokes, teasing, obscene or suggestive gestures and so on, it is more likely that an arbitrator or court will substitute a lesser penalty for discharge. Again there are some exceptions.