The arrest of an unmasked woman will face scrutiny by Victoria Police's professional standards command, amid calls for robust oversight of the force's expanded COVID-19 powers.
A 21-year-old woman from St Kilda became involved in an altercation on Monday after officers spotted her not wearing a mask in Collingwood.
Video has emerged of a male officer placing his hands around the woman's neck during the arrest.
"He's choking me. He's choking me. Get off of me. Get off," the woman yells.
She then lashes out at a female officer, kicking her in the chest, before being taken to the ground.
"Tell me what the f*** I've done?" the woman asks.
As she's led away to a police van, a male filming the arrest says: "She's got a note from the doctor. Youse are f***ed".
Police say she refused to provide her name and address and didn't state she had an exemption for disobeying coronavirus health requirements to wear a mask.
She was charged with resisting arrest and assaulting police and bailed to face court at a later date.
"She did not receive a fine for failing to wear a face-covering because she later told police she had an exemption," police said in a statement.
The arrest has been referred to Victoria Police's professional standards command for oversight.
On Tuesday, a 58-year-old woman was arrested at Frankston for allegedly assaulting a police officer after not wearing a mask at a cafe.
The incidents come as Aboriginal and Torres Strait Islander, legal and human rights bodies call for the Victorian government to guarantee new police powers are properly scrutinised.
In a joint statement on Tuesday, the group said the wide-ranging powers for police under Premier Daniel Andrew's "state of disaster" declaration must be complemented by an independent watchdog to ensure accountability.
"We don't want increased police powers to become the new normal - the powers must end as soon as the pandemic does," Human Rights Law Centre senior lawyer Monique Hurley said in the statement.
It pointed to a parliamentary committee's interim report, released last Tuesday, that showed Victoria's three poorest communities accounted for 10 per cent of COVID-19 fines over the first two months of restrictions.
That figure stands in stark contrast to the state's three most advantaged local government areas which copped 1.9 per cent of fines over the same period, raising concerns communities aren't being policed fairly.
Another 202 fines were dished out in the previous 24 hours from 4529 spot checks, police said on Tuesday.
They include 70 fines of $1652 for breaching Melbourne's 8pm-5am curfew and 33 fines of $200 for failing to wear a face mask.
A man told police he was practising to become a DJ when discovered in someone else's home.
Another found in his car at a Maribyrnong car park said he wanted some peace and quiet as his housemate was being "too loud in the bedroom" with their partner.