Constructive dismissal actions can be difficult to prove as there is a heavy burden on the employee in these actions, in our opinion. Not only is the burden of proof on the employee in this action, unlike an unfair dismissal action, but the employee must also show they exhausted all internal grievance mechanisms prior to the date of dismissal, and this can be an onerous duty in circumstances where the employee left the employment due to the conduct of the employer, which may have become unbearable, so in many instances the employee leaves too early without availing of each and every internal grievance procedure available, and then the employer relies upon this in such actions to successfully defend them on many occasions.