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C. An Express Break With Precedent in Health Services[166] While the basic framework set down in the Trilogy had stood for some 20 years, theCourt decided to break with this line of precedent in Health Services. In that case, the majorityheld that s. 2(d) protects a right to collective bargaining and imposes a duty on employers tobargain in good faith. Such a right could not be accommodated within the framework set downby the Trilogy and followed in subsequent cases, and so the majority opted to overturn that line2011 SCC 20 (CanLII)of precedents altogether.[167] The overarching reason advanced for rejecting the Trilogy’s interpretation of s. 2(d)was that it reflected a “decontextualized” rather than “purposive” approach to Charterinterpretation: Health Services, at para. 30. The majority in Health Services found thatinsufficient attention had been paid to the close connection between freedom of association andlabour relations (specifically trade unionism), and that the intimate ties between the two impliedthat s. 2(d) should be held to protect a broader set of entitlements than the Trilogy’s approachcould support. Under this view, the main problem with the Trilogy’s approach was that it did notextend a right to “collective bargaining”, the protection of which was, in the majority’s view, acentral purpose of freedom of association (para. 86).[168] In extending constitutional protection to collective bargaining, the majority in HealthServices viewed this constitutional right as including an obligation on parties to bargain in goodfaith. The majority in Health Services described the protection afforded under s. 2(d) as follows,at para. 90: