What constitutes a demotion as a constructive dismissal?

I agree, and it was not contested, that the change of the plaintiff’s job responsibilities in July, 1998, was a demotion, which could have been considered by the plaintiff as a constructive dismissal. As stated by Gonthier J. in Farber v. Royal Trust Co., 1997 CanLII 387 (SCC), [1997] 1 S.C.R. 846, at 865, “. . .a demotion, which generally means less prestige and status, is a substantial change to the essential terms of an employment contract that warrants a finding that the employee has been constructively dismissed.” At page 864, he stated: Thus, it has been established in a number of Canadian common law decisions that where an employer unilaterally makes a fundamental or substantial change to an employee’s contract of employment – a change that violates the contract’s terms – the employer is committing a fundamental breach of the contract that results in its termination and entitles the employee to consider himself or herself constructively dismissed. The employee can then claim damages from the employer in lieu of reasonable notice. (my emphasis) In dealing with the civil law, which he said is similar to the common law when it comes to the concept of constructive dismissal (at page 865), he noted that a constructive dismissal takes place when the employee does not agree to the changes and leaves his or her job (at page 858) (my emphasis).