How have courts interpreted the distinction between "freedoms" and "rights"?

One should not apply this distinction rigidly. Dickson C.J. warned that this conceptual approach might fail to capture "situations where the absence of government intervention may in effect substantially impede the enjoyment of fundamental freedoms". Similarly, in Haig v. Canada, 1993 CanLII 58 (SCC), [1993] 2 S.C.R. 995, [1993] S.C.J. No. 84, at p. 1039 S.C.R., L'Heureux-Dubé J. wrote for the majority that while the distinction between "rights" and "freedoms" may be helpful, it does not displace the purposive approach articulated [in] Big M Drug Mart, supra, and that in some circumstances "positive governmental action might be required" to secure a fundamental freedom.