If I recall correctly, for Commodores, the equivalent of the disk operating system was handled by the drive itself. If you wanted to do anything beyond a LOAD or a SAVE, you were effectively opening the device then sending a command to the device. The exception was getting a directory, which used the LOAD command (as described earlier) rather than a dedicated command. In my opinion, it is accurate to describe loading a special file in order to retrieve a directory listing as a trick.

Looking at the Apple II and Commodore 64, I think it is fair to say that while the BASIC environments supported varying degrees of disk command they were quite different from what we think of as command interpreters. With Unix shells, anything you can enter into a shell script can be executed from the command line, and vice versa. If memory serves me correctly, anything that could be done from the MS/PC-DOS command line could be done from a batch file (though I don't recall if the opposite is true).