Under COVID-19 measures, police officers have the power to fine individuals $1000 and businesses $5000 breaching public health orders or ministerial directions.

As of April 20, state police had issued 95 court notices and 736 penalty infringement notices, with on-the-spot fines, since March 17.

And while some of these cases are for people legitimately refusing to comply with social-distancing measures, solicitor Peter O'Brien says people are confused about what they are allowed to do and are being penalised unfairly.

"The lack of real clarity from the political masters who put in place this legislation is leading to an arbitrary application in the streets. People are genuinely and sincerely not certain of what a reasonable excuse is," Mr O'Brien told AAP.

"I'm concerned it's being applied to people who are already over-policed, the mentally ill, those fairly marginalised in society, most of whom can't afford to pay those penalties," he said.

"For a person who is a millionaire, the thousand dollar fine is nothing."

"It could be everything for someone who has nothing."

He recounted three young girls travelling together in a car, two of whom lived together. They thought it was lawful to travel with one other person and were surprised to learn this was illegal under the COVID-19 restrictions, and were fined for doing so.

And while NSW Police Commissioner Mick Fuller said he would personally review every penalty infringement notice handed out, Shooters Fishers and Farmers MP Phil Donato does not believe many fines will be withdrawn.

Mr Donato worked for 22 years as a police officer, with nearly 16 of them as a prosecutor in the courts.

"Very few matters initiated by police and reviewed by police were later withdrawn by the police," Mr Donato told AAP.

"I understand the intention of the legislation, but these new laws were not properly introduced, or fleshed out and debated in parliament, and it's led to a lot of confusion."

Mr Donato is unsure how Mr Fuller will keep up with the "sheer volume" of fines and personally review them all.

NSW Council for Civil Liberties president Stephen Blanks questions why some of these fines are in areas of NSW where no known COVID-19 infections exist.

"The ultimate purpose of these regulations is for protection of community health," Mr Blanks told AAP.

"There was a couple in Cobar who were fined for being outside their home. The police should take into account if the activity engaged by the couple did put the community at risk. I'm not sure there are currently any infections in Cobar."

Sydney University law lecturer Dr Carolyn McKay expressed concerns that some people who may have been penalised unfairly won't have the wherewithal to challenge it.

"It can be very difficult for people who are experiencing personal hardships in their life to keep on top of extraordinary things like this," she told AAP.

"And we're talking about really high penalties here. A lot of people aren't as aware as others of what is going on in the world, it's troubling to think they will be fined for this."

Australian Associated Press