The release included a full human rights waiver he signed without seeking legal advice
A disability. A productivity email. A release signed in three days. On February 18, 2026, Human Rights Tribunal of Ontario Vice-chair François Henrie dismissed a discrimination application by a former CI Investments Inc. employee, ruling the release he voluntarily signed barred him from proceeding. The case turns on what happened, and what didn’t, between a manager's email and a signature.
Peter Todorovic worked at CI Investments as a RESP Services Associate since November 2015. On August 18, 2020, he consulted an optometrist for vision problems and was referred to two specialists, with appointments only after September 29.
On August 27, his manager emailed him about a drop in productivity. Todorovic replied the same day that he had a health issue with one of his eyes and was waiting for an appointment with specialists.
On September 29, Todorovic was told his position was being eliminated due to restructuring and was terminated on a without-cause basis. He was presented with a cover letter and a Final Release and Indemnity Agreement outlining termination details, including separation allowances and benefits.
The release that closed every door
The cover letter included a clause stating the agreement "shall represent full and final release and discharge of any liability, including liability in pursuance to the Human Rights Code," and that the parties had "discussed any and all human rights complaints, concerns or issues arising out of or in respect of your employment or cessation of your employment."
The Final Release and Indemnity contained an additional clause: "I hereby acknowledge that I have not been subjected to any form of discrimination whatsoever and hereby represent and warrant that I have not commenced any complaint and undertake not to commence any complaint under the applicable Human Rights Code or similar legislation."
The document also confirmed Todorovic had "been afforded an opportunity to independently review and read and obtain independent legal advice" and was executing it "freely, voluntarily and without duress." He was given until October 13 to sign and signed on October 2, three days after receiving it.
What came after the release
Todorovic filed his application on January 11, 2021. He argued no human rights discussions had taken place, rendering the release invalid, and that he signed under great mental and emotional distress. The Tribunal found no evidence of duress and noted he could have raised discrimination issues before signing but chose not to.
On November 16, 2020, his ophthalmologist confirmed the applicant had an eye condition that would have required an accommodation "at that time." Four days later, Todorovic emailed the respondent questioning settlement amounts and the absence of human rights discussions, noting "I have not filed anything to date in accordance with the severance agreement I signed."
In his own submissions, Todorovic "confirmed that after signing the Release, he took steps to learn about the Code and decided to file this Application." The Tribunal found he "should have taken these steps prior to signing the release and not after." Vice-chair Henrie dismissed the application as an abuse of process, citing the Tribunal's earlier ruling in Dunn v. Sault Ste. Marie (City), 2008 HRTO 149, that "there is a strong public interest in ensuring that when parties freely choose to resolve the substance of a human rights dispute, in whatever form it is brought, the matter is at an end."
