What Argument Did the Supreme Court of Canada in Dowling

What argument did the Supreme Court of Canada in Dowling v.Halifax [1998] 1 S.C.R.22 refuse to accept from an employer that sought to reduce the claim of a worker who had been wrongfully dismissed?

A) that any act of dishonesty justifies termination
B) that dismissal without notice is justified during economic setbacks
C) that 'near cause' justifies a reduction in damages for wrongful dismissal
D) that reasonable notice should be limited to notice set out in statute