Is there any case law supporting the argument that access as a separate juridical concept from statute?

Manitoba, Canada


The following excerpt is from A.J.C. v. A.G., 2001 MBQB 175 (CanLII):

Wilson J. stated in Frame v. Smith, 1987 CanLII 74 (SCC), [1987] 2 S.C.R. 99 at 130: I believe that there is considerable support for the view that access as a distinct juridical concept is purely a creature of statute.

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