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In this phrase:

Le fait que l'univers obéisse a des lois

There's no doubt the universe obeys laws, and so using the subjunctive jars - it feels incongruous for something so certain. It is acceptable to use the indicative in some cases

Le fait que l'univers obéit a des lois

or is the subjunctive always used?

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The subjunctive is still used often enough independently of the nature of fact (whether hypothetical or not), nevertheless the important number of cases of use of the indicative makes that choice an option, especially in those contexts where it is a question of a verified fact. A great number of cases of use of the indicative are given on this page.

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