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The arrest of an unmasked woman in Melbourne's inner north will be scrutinised by Victoria Police's professional standards command.
The 21-year-old St Kilda woman became involved in an altercation on Tuesday afternoon after officers spotted her not wearing a mask in Collingwood.
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.
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".
She was charged with resisting arrest and assaulting police and bailed to face court at a later date, but escaped a fine for not wearing a mask as "she later told police she had an exemption".
"The arrest has been referred to Professional Standards Command for oversight," Victoria Police said in a statement on Tuesday.
The female officer was taken to hospital for observation.
Victoria Police have conducted 4529 spot checks on homes, businesses and public places in the past 24 hours and fined 202 people.
They include 70 people fined $1652 for breaching Melbourne's 8pm-5am curfew and 33 fined $200 for failing to wear a face mask.
Three people were fined on Monday after a video surfaced of them filming themselves going out about 2.30am on Sunday to buy take away in Melbourne's CBD.
Another man was fined when he told police he was practising to become a DJ when discovered in someone else's home.
A man found more than 5km from his home in his vehicle at a Maribyrnong car park on Sunday evening explained he was out for some peace and quiet as his housemate and their intimate partner were being "too loud in the bedroom".
He too was fined, as were multiple people caught running the gauntlet to pick up food, cigarettes or milk at metropolitan convenience stores outside curfew hours.