A female Victoria Police officer's head was allegedly repeatedly "smashed" into concrete last night by a woman who refused to wear a mask, police said.
There has also been a disturbing rise in people incorrectly claiming "sovereign citizenship" to try and evade fines and restrictions, with police busting through car windows on multiple occasions.
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The 26-year-old officer who was allegedly attacked had been on patrol with partner in the Frankston area near the Bayside shopping centre.
"During that time they approached a 38-year-old woman who wasn't wearing a mask," Chief Commissioner Shane Patton said.
"After a confrontation and being assaulted by that woman, those police officers went to ground and there was a scuffle.
"During that scuffle, this 38-year-old woman hit the head, smashed the head of the policewoman several times into a concrete area on the ground."
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Commissioner Patton said the woman, who had no previous criminal history, had been charged with significant offences.
"That's someone who thinks they're above the law," he alleged.
The police officer that received significant head injuries was taken to the Frankston Hospital for assessment and medical treatment.
Police handed out 160 infringement notices in the past 24 hours, including 60 for people not wearing masks.
Commissioner Patton said in the past week police had noted "an emergence" of small groups of people who classify themselves as "sovereign citizens, whatever that might mean".
These were "people who don't think the law applies to them".
Commissioner Patton said those people were "baiting" police at checkpoints, and refusing to provide identification.
"On at least three or four occasions in the past week, we've (had) to smash the windows of people in cars and pull them out of there so they could provide their details because they weren't telling us where they were going," Commissioner Patton said.
"They weren't adhering to the Chief Health Officer guidelines, they weren't providing their name and their address.
"We don't want to be doing that. But people have to absolutely understand, there are consequences for your actions, and if you're not doing the right thing, we will not hesitate to issue infringements, to arrest you, to detain you where it's appropriate."
Overnight, police intercepted someone who was driving to a bottle shop at 3am to get alcohol.
"That's not acceptable," Commissioner Stokes said.
Police said they also stopped a group of people coming back from McDonald's with burgers.
A driver was also pulled over after the 8pm curfew for driving across the city to buy a car.
In the past 24 hours police checked 22,091 vehicles checkpoints and teams conducted 6033 spot checks on people at homes, businesses and public places across the state.
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