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HRTO Application — Narrative and Submissions (Ontario)
The Human Rights Tribunal of Ontario gives you a form to fill in; it does not tell you how to win. The official Form 1 captures who and what, but the case is made in the narrative — and applications fail far more often on weak framing than on weak facts. Our Canadian template writes the submissions you attach to the application: the protected ground mapped to the adverse impact in the right social area, the Supreme Court of Canada’s prima facie test set out element by element, an incident log that proves a pattern, and a remedy schedule built the way the Tribunal actually orders. It is the difference between a complaint that gets screened out and one that gets heard.
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Human Rights Application — Narrative and Submissions
Submissions For A Form 1 Application To The Human Rights Tribunal Of Ontario — Disability In Employment · June 11, 2026
Dwayne A. Okafor
88 Sherbourne Street, Unit 12, Toronto ON M5A 2R7
+1 (416) 555-0142
dwayne.okafor@email.ca
June 11, 2026
Human Rights Tribunal of Ontario
Tribunals Ontario
Attached to Application (Form 1)
Attached to Application (Form 1)
HUMAN RIGHTS CODE APPLICATION — SUBMISSIONS
Disability · Employment
To the Human Rights Tribunal of Ontario,
I make this application under the Human Rights Code (Ontario). I am an applicant who has experienced discrimination on the ground of disability in employment, and these submissions accompany my Form 1. They set out who the respondents are, the ground and the area, what happened, why the Code was infringed, and the remedies I ask the Tribunal to order.
I make this application under the Human Rights Code (Ontario). I am an applicant who has experienced discrimination on the ground of disability in employment, and these submissions accompany my Form 1. They set out who the respondents are, the ground and the area, what happened, why the Code was infringed, and the remedies I ask the Tribunal to order.
1.
THE APPLICANT AND THE RESPONDENTS
Applicant: Dwayne A. Okafor
Address: 88 Sherbourne Street, Unit 12, Toronto ON M5A 2R7
Telephone: +1 (416) 555-0142
Email: dwayne.okafor@email.ca
Primary respondent: Northbridge Logistics Inc. — my former employer
Additional respondents: Kevin Marsh, Operations Manager (named personally for the conduct described)
An employer is generally responsible for discrimination by its officers, managers and employees in the course of their work, and individuals who personally engaged in the conduct may also be named as respondents.
Address: 88 Sherbourne Street, Unit 12, Toronto ON M5A 2R7
Telephone: +1 (416) 555-0142
Email: dwayne.okafor@email.ca
Primary respondent: Northbridge Logistics Inc. — my former employer
Additional respondents: Kevin Marsh, Operations Manager (named personally for the conduct described)
An employer is generally responsible for discrimination by its officers, managers and employees in the course of their work, and individuals who personally engaged in the conduct may also be named as respondents.
2.
THE GROUND AND THE SOCIAL AREA
This application is about discrimination on the ground of disability, in the social area of employment. The Code protects against discrimination on enumerated grounds within defined social areas; both the ground and the area must be made out, and they are identified here so the application is framed correctly from the outset.
3.
WHAT HAPPENED
In summary: After I disclosed a back injury and provided a note recommending a lifting restriction, my hours were cut, I was moved off the routes I had held for two years, and I was dismissed three weeks later — while less senior workers without restrictions kept their shifts.
The detailed chronology, the connection between the ground and the treatment, and the supporting evidence are developed in the submissions that follow.
The detailed chronology, the connection between the ground and the treatment, and the supporting evidence are developed in the submissions that follow.
4.
TIME LIMIT
An application must be made within one year of the incident, or within one year of the last incident in a series of related incidents. The last incident relevant to this application occurred on April 9, 2026, which places the filing deadline on or about April 9, 2027. Where a series of related incidents is alleged, the clock runs from the last of them — the chronology below is set out with that in mind.
5.
REMEDY SOUGHT
I ask the Tribunal to find that the Code was infringed and to order the following: Compensation for injury to dignity, feelings and self-respect; lost wages from the date of dismissal; and an order that the respondent put a written accommodation procedure in place and train its supervisors on the duty to accommodate.
The Tribunal can order monetary compensation, compensation for other losses such as lost wages, and non-monetary or public-interest remedies; the remedy is developed further in the submissions below.
The Tribunal can order monetary compensation, compensation for other losses such as lost wages, and non-monetary or public-interest remedies; the remedy is developed further in the submissions below.
6.
THE PRIMA FACIE CASE
The test for discrimination is settled by the Supreme Court of Canada in Moore v British Columbia (Education), 2012 SCC 61. An applicant makes out a prima facie case by showing three things: (1) a protected characteristic; (2) an adverse impact in a protected social area; and (3) that the characteristic was a factor in that adverse impact. The ground need not be the only or the main reason — it is enough that it was a factor (Stewart v Elk Valley Coal Corp, 2017 SCC 30). Once the prima facie case is shown, the burden shifts to the respondent to justify the conduct; an unjustified infringement is discrimination.
(1) The protected characteristic — disability: I have a lumbar spine injury that limits repetitive heavy lifting. It is a disability within the meaning of the Code; I disclosed it and supported it with a practitioner’s note describing the functional restriction, without a diagnosis.
(2) The adverse impact in employment: Within days of disclosing the restriction my weekly hours fell from 40 to 22, I was removed from my regular routes, and on April 9, 2026 I was dismissed for "operational reasons" with no accommodation ever discussed.
(3) The characteristic as a factor: The timing ties the treatment to the disclosure: nothing about my performance had changed, and the only new fact was the lifting restriction. Two less senior drivers without restrictions were kept on the routes I had held.
Comparison / context: The two retained drivers, Sandford and Beaulieu, had each less than a year of service and no restriction on file; I had two years and a clean record.
(1) The protected characteristic — disability: I have a lumbar spine injury that limits repetitive heavy lifting. It is a disability within the meaning of the Code; I disclosed it and supported it with a practitioner’s note describing the functional restriction, without a diagnosis.
(2) The adverse impact in employment: Within days of disclosing the restriction my weekly hours fell from 40 to 22, I was removed from my regular routes, and on April 9, 2026 I was dismissed for "operational reasons" with no accommodation ever discussed.
(3) The characteristic as a factor: The timing ties the treatment to the disclosure: nothing about my performance had changed, and the only new fact was the lifting restriction. Two less senior drivers without restrictions were kept on the routes I had held.
Comparison / context: The two retained drivers, Sandford and Beaulieu, had each less than a year of service and no restriction on file; I had two years and a clean record.
7.
INCIDENT LOG, COMPARATORS AND REPRISAL
Discrimination is usually proved by a documented pattern, not a single sentence. The dated log below sets out each incident, who witnessed it and what records support it:
1. March 16, 2026 — Gave my supervisor the practitioner note with the lifting restriction — witness(es): Reception logged the note; copy kept — document(s): Practitioner note; email confirming receipt
2. March 20, 2026 — Weekly hours cut from 40 to 22 and removed from regular routes — witness(es): Dispatch records — document(s): Schedule screenshots (before/after)
3. April 9, 2026 — Dismissed for "operational reasons"; no accommodation ever offered — witness(es): Kevin Marsh present — document(s): Termination letter
The pattern: The sequence — disclosure, immediate reduction, removal from routes, dismissal within three weeks — shows the restriction, not performance or operations, drove the decisions.
1. March 16, 2026 — Gave my supervisor the practitioner note with the lifting restriction — witness(es): Reception logged the note; copy kept — document(s): Practitioner note; email confirming receipt
2. March 20, 2026 — Weekly hours cut from 40 to 22 and removed from regular routes — witness(es): Dispatch records — document(s): Schedule screenshots (before/after)
3. April 9, 2026 — Dismissed for "operational reasons"; no accommodation ever offered — witness(es): Kevin Marsh present — document(s): Termination letter
The pattern: The sequence — disclosure, immediate reduction, removal from routes, dismissal within three weeks — shows the restriction, not performance or operations, drove the decisions.
8.
THE REMEDY SCHEDULE
The Tribunal orders remedies on three tracks, and a well-structured application addresses each. Injury to dignity, feelings and self-respect is compensated as a single global figure assessed on the seriousness of the conduct and its effect on the applicant — there is no statutory cap.
Injury to dignity — my position: The conduct was serious: I was treated as a problem to remove rather than a worker to accommodate, the dismissal followed disclosure of a health condition, and the effect on my confidence and finances was significant. A dignity award in the mid range reflects the seriousness and the vulnerability involved.
Monetary losses (lost wages and other losses):
1. Lost wages (dismissal to date, 22 h/week shortfall then full loss) (Mar 20 – Jun 2026) — $11,400.00
2. Continuing lost wages until comparable work is found (ongoing) — to be quantified
Public-interest / non-monetary remedies: An order that the respondent adopt a written accommodation procedure and train supervisors on the duty to accommodate, so that the next worker who discloses a restriction is engaged rather than removed.
Injury to dignity — my position: The conduct was serious: I was treated as a problem to remove rather than a worker to accommodate, the dismissal followed disclosure of a health condition, and the effect on my confidence and finances was significant. A dignity award in the mid range reflects the seriousness and the vulnerability involved.
Monetary losses (lost wages and other losses):
1. Lost wages (dismissal to date, 22 h/week shortfall then full loss) (Mar 20 – Jun 2026) — $11,400.00
2. Continuing lost wages until comparable work is found (ongoing) — to be quantified
Public-interest / non-monetary remedies: An order that the respondent adopt a written accommodation procedure and train supervisors on the duty to accommodate, so that the next worker who discloses a restriction is engaged rather than removed.
9.
FORUM, TIMING AND PROCESS
This application is made within one year of the last incident, and is in time.
Forum: I am pursuing this matter at the Tribunal and have not commenced a court action seeking Human Rights Code remedies on the same facts.
Filing this application is free, and the Tribunal offers mediation in many cases, which I am willing to consider provided any resolution properly addresses the infringement and the remedy.
Representation: I am seeking advice and possible representation from the Human Rights Legal Support Centre, which assists applicants at no cost.
Forum: I am pursuing this matter at the Tribunal and have not commenced a court action seeking Human Rights Code remedies on the same facts.
Filing this application is free, and the Tribunal offers mediation in many cases, which I am willing to consider provided any resolution properly addresses the infringement and the remedy.
Representation: I am seeking advice and possible representation from the Human Rights Legal Support Centre, which assists applicants at no cost.
10.
CONCLUSION
I ask the Tribunal to accept these submissions with my application, to find that the Human Rights Code was infringed, and to order the remedies sought. I am prepared to provide further particulars, documents and witness information as the proceeding requires, and I reserve all my rights under the Code.
RESPECTFULLY SUBMITTED,
Dwayne A. Okafor
Applicant
Date: ____________________
APPLICANT
Dwayne A. Okafor
Date: ____________________
Available as a print-ready PDF or an editable Microsoft Word (.docx) file.
What Is an HRTO Application Narrative?
It is the submissions document that carries your case. An application to the Human Rights Tribunal of Ontario (HRTO) starts with Form 1, but the form is a container — the substance is the narrative that explains how the Human Rights Code was infringed. The Code prohibits discrimination on enumerated grounds (disability, race, sex and pregnancy, family status, age, creed and others) within defined social areas (employment, housing, goods and services, contracts, vocational associations). Both the ground and the area have to be made out, and the narrative is where you do it. This template writes that narrative for you and leaves the official Form 1 to capture the bare particulars.
The legal test is settled by the Supreme Court of Canada. In Moore v British Columbia (Education), 2012 SCC 61, the Court fixed the prima facie test at three elements: a protected characteristic, an adverse impact in a protected area, and the characteristic being a factor in that impact. The third element is where most applications stumble — applicants describe being hurt without showing why the ground was a reason. The law is generous here: Stewart v Elk Valley Coal Corp, 2017 SCC 30 confirms the ground need only be a factor, not the sole or primary cause. But the link still has to be shown, usually through timing, comparators and the absence of any other explanation, and the template writes each element explicitly so the connection is on the page.
Two things decide whether the application even survives to a hearing in Ontario: timing and forum. An application is generally out of time after one year from the incident (or the last incident in a series), and a late one survives only on a good-faith explanation with no substantial prejudice. And you cannot run an HRTO application and a court claim for Code remedies on the same facts at once, nor re-litigate what a workers’ compensation process has already appropriately dealt with — the principle the Supreme Court set in Figliola, 2011 SCC 52. The template fixes your timing position and clears the forum questions before they become a dismissal.
What's Covered in This Template
The submissions are structured the way the Tribunal reviews them — parties, ground and area, the prima facie case, the evidence, the remedy and the forum — so the application is built to be heard, not screened out.
Ground and Social Area
The protected ground (disability, race, sex and pregnancy, family status, age, creed or another) mapped to the right social area — employment, housing or services — so both halves of the claim are made out.
The Moore Prima Facie Test
The Supreme Court of Canada’s three-element test written explicitly: protected characteristic, adverse impact, and the characteristic as a factor — the third element built around your facts.
The "Factor" Standard
Framed on Stewart v Elk Valley: the ground need only be a factor, not the only or main reason — shown through timing, comparators and the absence of another explanation.
Incident Log with Witnesses
A dated, numbered chronology — date, event, witness, document — that turns a story into evidence and exposes the pattern an adjudicator reads first.
Reprisal as a Separate Claim
Where it applies, the reprisal allegation — punishing you for asserting a Code right — which stands even if the underlying discrimination is not made out.
Injury-to-Dignity Positioning
The remedy where positioning matters: HRTO dignity awards commonly fall in the $10,000–$40,000 band, with serious cases higher and no statutory cap — argued on seriousness and impact.
Monetary Loss Schedule
Lost wages, benefits and out-of-pocket losses itemized and tied to the discrimination — the second remedy track, built to be proved.
Public-Interest Remedies
The orders that cost the respondent little and protect the next person — a policy, training or a systemic change — and signal the case is about more than money.
One-Year Limit, Computed
The s.34 deadline calculated from your last incident, with the good-faith extension positioned if any part of the application is late.
Forum Traps Cleared
The court election (you cannot do both) and the workers’-compensation overlap (Figliola) handled before they become a reason to dismiss.
How to Create Your HRTO Submissions
Five steps from a sense of unfairness to a hearing-ready application.
- 1
Name the Parties
You and the respondents — usually your employer, and any individual who personally engaged in the conduct, who can be named alongside it.
- 2
Pick the Ground and Area
The protected ground and the social area it happened in — the template frames the legal test that matches.
- 3
Date the Last Incident
The one-year clock runs from here; for a series of related incidents, use the last one — the template computes your deadline.
- 4
Build the Prima Facie Case (Expert)
The three Moore elements, an incident log with comparators and reprisal, and a remedy schedule across all three tracks.
- 5
Clear the Forum and File
Fix your timing position, settle the court and workers’-comp questions, and attach the submissions to your Form 1 — filing is free.
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Legal Considerations
Human rights applications in Ontario are won on framing as much as facts — and lost on deadlines and the wrong forum.
This template provides general information for applicants in Ontario and is not legal advice. The one-year limit under the Human Rights Code is strict; if your deadline is near, or the matter overlaps with a dismissal, a workers’ compensation claim or a court action, get advice from a human rights or employment lawyer. The Human Rights Legal Support Centre offers free legal assistance to applicants. This template covers Ontario; other provinces and the federal system have their own tribunals and rules.
Reviewed for Ontario human rights law
HRTO, OHRC and HRLSC — Three Different Bodies
These are constantly confused, and sending your application to the wrong one wastes time you may not have. The Human Rights Tribunal of Ontario (HRTO) is where you file and where your application is decided — it is the destination for this document. The Human Rights Legal Support Centre (HRLSC) is a separate service that gives applicants free legal advice and can represent you. The Ontario Human Rights Commission (OHRC) does policy, research and public education — it does not take or decide individual applications. The template addresses the application to the HRTO, where it belongs.
The Moore Test, and Why the Third Element Decides It
Moore v British Columbia (Education), 2012 SCC 61 sets the test: a protected characteristic, an adverse impact, and the characteristic as a factor in that impact. The first two are usually easy; the case turns on the third — the link. Stewart v Elk Valley Coal Corp, 2017 SCC 30 keeps the bar low (a factor, not the factor), but the connection still has to be shown. Timing, comparators (how people without the characteristic were treated) and the absence of any innocent explanation are the tools, and the template writes them in.
The One-Year Limit and the Series Rule
An application must be made within one year of the incident under s.34(1) of the Code, or within one year of the last incident in a series of related ones. A late application survives only if the Tribunal is satisfied the delay was in good faith and causes no substantial prejudice (s.34(2)). The series rule cuts both ways: a recent incident can pull older, related conduct back into time. The template computes the deadline from your last incident and positions the extension if any part is late.
Forum Choice — Court, and Workers’ Compensation
There is no stand-alone court application for a Code breach; a court awards Code remedies only inside another claim, such as a wrongful dismissal action — and you cannot run a Tribunal application and that court claim on the same facts at once (s.34(11)/s.46.1). Separately, where the same workplace events were dealt with through a WSIB claim, the Tribunal can decline the application as already appropriately dealt with (Figliola, 2011 SCC 52). If the workplace-injury side is live, our WSIB Intent to Object template handles that route, and the two questions are kept distinct.
Related Canadian Templates
Discrimination cases rarely stand alone. If the discrimination took the form of a refused accommodation, our workplace accommodation request starts the duty-to-accommodate process; if it ended in dismissal, our severance review demand letter prices the common-law claim and our CLC unjust dismissal complaint covers federally regulated employees. Where the conduct is harassment, our workplace harassment investigation request triggers the employer’s duty to investigate, and our employer-side workplace harassment and violence policy shows the standard employers are held to. For unpaid wages alongside, see our employment standards complaint support letter.
Frequently Asked Questions
Make the Application That Gets Heard, Not Screened Out
Create your HRTO submissions in minutes: the ground and area framed correctly, the Supreme Court of Canada’s Moore test set out element by element, a documented incident log, a three-track remedy schedule, and the one-year limit and forum traps cleared — in formal submissions format. Download the PDF free, or unlock Expert for the prima facie framework, the incident log and the remedy schedule.
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