Police said this trend included so-called "sovereign citizens" - who espouse an anti-government ideology - confronting officers.

In one case a woman repeatedly smashed a policewoman's head into the ground.

Authorities have increased fines for repeated rule breaches as Melbourne endures a deadly virus second wave.

More than half of Australia's 18,300 cases have been recorded in the past month in Victoria, of which Melbourne is the capital. There have been 226 deaths nationally.

Melbourne has recently mandated wearing masks and tightened a stay-at-home order to reduce transmissions.

But authorities said many people were breaking rules, including some who claimed to be "above the law".

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