"Why would people think that is OK? I think there is no question when Victoria Police pull people over they are aware of the rules but have made a decision to blatantly breach the Chief Health Officer's directives," she said.

“If you are thinking of using back roads or getting around these walls, Victoria Police will be there."

People have also been caught partying at Airbnbs on Franklin Street in the CBD and on Dudley Street in West Melbourne.

Ten people were fined at the West Melbourne address at 11pm after police received noise complaints, with two people found hiding in a bathroom when officers arrived.

At 2am on Saturday, five people in a short-stay apartment on Franklin Street received $1652 fines, with "some attempting to avoid police detection by hiding in a closet", according to a Victoria Police spokeswoman.

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 infringements in the last 24 hours were for those stopped at vehicle checkpoints. More than 24,761 checks have been completed by Victoria Police checkpoints on arterial roads.

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Other examples of breaches from the last day 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.

Premier Daniel Andrews said the government was considering hiking up penalties for breaching the Chief Health Officer’s directions.

“There are significant penalties and we are looking at whether we need to change any of those penalties,” he said on Saturday.

“There are options available to us whether it be on the spot fines versus finding people through the courts, that is a much bigger fine, but there is a balance to be struck there and we will find that balance.”