The above analysis reviews cases which either preceded present human rights legislation offering protections on the basis of family or marital status or did not involve human rights issues.

In circumstances which there may be a contractual obligation to relocate, or where the issue focuses on the argument of the implied term, there may will be possible human rights arguments which may be advanced by the employee.

The employee may have a family obligation which rises to the status of protected human right, as reviewed here, which may militate against the move.

A similar submission may be made where the employer chooses to relocate only single persons, as is discussed here on the issue of marital status, which includes adverse treatment shown to a non-married person.

There may also be a disability which requires accommodation.

To date, these issues have not been argued. This may change.