So how should peaceful be understood and why should an assembly remain protected even when it is noisy or obstructive?

Okay, so I mean, this is the key question under Section 2C.

And so as you pointed out, Section 2C protects freedom, not freedom of assembly, but freedom of peaceful assembly.

And so it's the qualifier to the entitlement under Section 2C.

And therefore it's a central variable.

And it's also a very difficult variable to address because from the one point, from one point of view, it is the purpose of gatherings and assemblies, not all of them, but many of them to gain attention for their message through deliberately disruptive strategies.

That's the point of many gatherings and demonstrations.

What does the case tell us about the tension between the freedom of peaceful assembly and property rights?