What is the definition of "wages" under The Labour Standards Act, 1969?

What the respondent has claimed is included in the definition of “wages” as set out in The Labour Standards Act, 1969. The appellant contends that the respondent is then limited to the remedies of recovery set out in that Act and is denied his common law action of recovery. In support of its contention the appellant relies upon the decision in Pateman v. Ray’s Ambulance Service Ltd., 1973 CanLII 899 (SK QB), [1973] 5 W.W.R. 709, 38 D.L.R. (3d) 709 (Sask.).

In Pateman v. Ray’s Ambulance Service Ltd., Tucker J. was considering a claim for overtime wages. In considering the effect of The Labour Standards Act, 1969, he made reference to the classification of statutes as set out in 36 Hals. (3d), 440, para. 665, which reads as follows: “665. Classification of statutes. For the purpose of establishing liability to individuals in civil actions founded on them, statutes may be divided into three classes, namely, (1) those in which a liability is affirmed which already exists at common law, and a special and peculiar form of remedy, different from that existing at common law, is given; (2) those in which a liability not previously existing at common law is created, but no particular form of remedy is provided; and (3) those in which a liability not existing at common law is created and a special remedy is provided.”