Authorities in the virus-stricken city of Melbourne have warned of a "dangerous" rise in people resisting lockdown measures, sometimes violently.
Police said this trend included so-called "sovereign citizens" being combative with officers in recent days.
In one case a woman repeatedly smashed a policewoman's head into the ground, Chief Commissioner Shane Patton said.
Authorities have increased fines for repeated rule breaches as Melbourne endures a deadly virus second wave.
Over 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".