What are the relevant principles relevant to this application?

In considering the three cases noted above, it is my view that the important principles relevant to this application are: 1. the facts relating to the point of law must not be in dispute and the point of law must be capable of being resolved without hearing evidence; 2. the determination of the questions must be decisive of the litigation or a substantial issue raised in it; 3. constitutional issues are not necessarily precluded from the scope of Rule 34; and 4. in the interpretation of contracts "facts known to the parties prior to the execution of the contract are admissible to identify the meaning of a descriptive term" Delisle v. Bulman Group Ltd..