The B.C. Supreme Court recently considered the legal framework surrounding employee retirements in Pringle v. Ritchie-Smith Feeds, Inc., 2025 BCSC 1211 (“Pringle”). The decision provides helpful guidance on when a retirement becomes legally binding—and whether an employee can later change their mind. David Penner, partner at Harris & Company, represented the employer in this case.
Background
The case involved a wrongful dismissal claim brought by Mr. Pringle, who had worked for the Defendants for decades. Mr. Pringle argued that although he had discussed his retirement with the Defendants, no specific date had been agreed upon, and he did not wish to retire. Mr. Pringle argued that his employment was wrongfully terminated when the employer purported to terminate him without giving him reasonable notice. The Defendants, on the other hand, asserted that Mr. Pringle had voluntarily retired by mutual agreement—and only later tried to change his mind.
The Court reviewed several informal discussions that had taken place between Mr. Pringle and the Defendants’ General Manager, ultimately concluding that Mr. Pringle had communicated a voluntary, clear, and unequivocal offer to retire, which the Defendants accepted. Based on this, the Court dismissed Mr. Pringle’s wrongful dismissal claim, finding that the Defendants were entitled to treat the employment relationship as ending on the agreed-upon retirement date. No wrongful dismissal occurred.
Legal Framework
The Court in Pringle affirmed that the legal character of retirement is that it constitutes a voluntary decision by the employee to terminate or repudiate the employment contract, typically on a future date. The Court relied on the B.C. Court of Appeal’s decision in Beggs v. Westport Foods Ltd., 2011 BCCA 76, which held that a finding of resignation (or retirement) requires both:
However, Pringle acknowledged that the role of the employee’s subjective intent has been treated inconsistently in the case law. To reconcile these authorities, the Court adopted the reasoning in Conway v. Griff Building Supplies Ltd., 2020 BCSC 1899, and held that the subjective element is limited to what would have been apparent to a reasonable employer at the time. In other words, it’s not what the employee may have intended, but what their words and actions conveyed objectively.
Can an Employee Change Their Mind?
The Court confirmed that, in certain circumstances, an employee may change their mind about retiring—but only before the employer has accepted the retirement or relied on it to their detriment. In Pringle, this threshold had already been crossed: Mr. Pringle had made a clear and unequivocal offer to retire, which the Defendants accepted. As a result, he could not later resile from his decision to retire.
Detrimental Reliance
While the Court did not need to decide the case based on detrimental reliance, it acknowledged that an employer may be entitled to enforce a retirement promise if it has relied on the employee’s stated retirement plans to its detriment—for example, by restructuring the business or hiring a replacement.
Key Takeaways for Employers
The Pringle decision provides welcome clarity for employers and reinforces the value of clear communication and careful documentation in managing employee exits, particularly those involving retirement.
The Pringle decision affirms that:
If you have any questions about this decision, please contact David Penner, or your Harris lawyer.
