The Supreme Court, with judg. n. 618/2017 held that (confirming the most recent case law) the burden of proof concerning the impossibility of worker's relocation it's solely to the employer.

In fact, allowing that it is up to the employee the onus to identify al the duties carried out by other employees, it would be contrary to the principle of the closeness' proof: proving circumstances and facts which are not within its direct knowledge will be too hard and difficult.

 

At the link below you can view the judgement:

ttp://www.cortedicassazione.it/corte-di-cassazione/it/homepage.page