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[177] There are five reasons why the collective bargaining right recognized by HealthServices is inconsistent with the purpose of s. 2(d). First, the analysis in Health Servicesimproperly assigned collective dimensions to an individual right. Second, Health Servicesassigned positive obligations to the essentially negative freedom of association. Third, thereasons in Health Services replaced a content-neutral approach to s. 2(d) freedom and adopted anapproach to s. 2(d) which privileges certain associations over others. Fourth, Health Services2011 SCC 20 (CanLII)elevated contracts — collective bargaining agreements — above statutes and disrupted theordinary hierarchy of laws. Fifth, the analysis in Health Services departs from a long-standingprinciple of judicial deference in the field of labour relations.(1) Section 2(d) Protects Individual Interests, Not Group Interests(a)Individual Freedoms Versus Collective Rights[178] First, Health Services reinterpreted an individual freedom as giving rise to collectiverights with no individual rights foundation. This reinterpretation of the scope of s. 2(d) was adeparture from previous jurisprudence that is not justified by the purpose of the Charterguarantee. The series of cases beginning with the Alberta Reference established that the freedomof association is an individual freedom which is intended to prevent the government frominterfering with associations by treating groups differently than it treats individuals.[179] Health Services expanded s. 2(d) to protect collective rights which meant thatindividuals who are members of specific groups now enjoy greater constitutional rights thanthose who are not. In particular, following Health Services, workers’ associations enjoy a robust