Other examples of breaches from the 24 hours include a man who travelled from Bentleigh East to Sunbury for his favourite take-away food, and another man who travelled from Thornbury to Werribee to get a haircut from his favourite barber.

Victoria Police Deputy Commissioner Rick Nugent said police members will continue to man arterial checkpoints at 2am in freezing conditions because of a group of "blatantly selfish" individuals.

"What we're seeing is too many individuals who are going about their lives as if this pandemic doesn't exist," he said.

"We don't want to be giving out fines for these sorts of things. There's a whole heap of activities we'd rather be doing, like engaging with and working with the community to keep them safe."

Eighteen of the 168 infringements in the last 24 hours were for those caught at vehicle checkpoints.

More than 24,761 checks have been completed by Victoria Police at checkpoints on arterial roads.