I thought he was refused a climb, not a track change. The normal reply is 'unable', which simply means you would be in conflict with someone else. If the weather were that bad, the entire stream would be moving around it.
In any event ATC cannot force you to fly through anything...behind is always an option.
I was wondering that, jb. So if left, right and upwards are no option due to other traffic, would you just go into a hold pattern until traffic cleared and then climb?