Does the promotion of human rights influence the evolution of complaints about the union duty of fair representation in Quebec (1978-2005)?

As a counter-balance to trade unions' representative monopoly, Quebec unions have since 1978 been held answerable to the duty ofeven-handed representation. Likewise, owing to the enactment of Quebec human rights statutes and charters since the 1970s, the promotion of human rights has led some observers to fear the interactive effects of two very different fields of legal intervention (human rights and group relationships based upon Labour Law), and also, the disruptive effects of logical reasonings centred on individual interests. As such, the authors empirically delve into the evolution of recourses for neglect of one's duty for providing even-handed representation by reviewing all the rulings handed down under subsection 47.3 of the Labour Code. While they fall short of observing that recourses based upon a condition protected by human rights legislation are increasing, they nonetheless note that precedents regarding the duty to even-handed representation have led them to question the weak protection afforded to the standard of equality in the field of labour law that permits the enforcement of subsection 47.3. The Parry Sound decision handed down in 2003 could, however, usher in the era of a reverse trend.