Maybe you're referring to some papers that used to come out a few years ago which suggested that leakage power will dominate total power. As I said above, this is unlikely to happen. It doesn't make sense to operate at a combination of supply voltage (Vdd) and threshold voltage (Vt) where leakage dominates total power. I think these papers misunderstood the fact that threshold voltage and hence leakage itself is a knob that the device manufacturing folks can control.

Active power is the one that's related to the frequency (P ~= CV^2f). Leakage power will "leak" even if the transistor is not switching.

If you're implying that leakage power doesn't affect frequency, you are wrong. Transistor speed depends on the gate overdrive which, for modern velocity-saturated devices is proportional to Vdd-Vt. Leakage power itself is proportional to exp(-Vt). There is a clear trade-off here between how fast you run your chip and how much it will leak.