Victoria's Police Association says the courts have given crime the green-light, after a teenager who kicked an officer to the head was allowed to walk free.

The 17-year-old has been sentenced to a nine month probationary order by the Children's court, despite already being on probation at the time of the attack for unrelated crimes.

A result Police Association Secretary Wayne Gatt has labelled "unacceptable."

"If you're allowed to target police officers and get away with it, we're effectively green-lighting crime in Victoria," he said.

The officer received several facial injuries after being kicked in the face. (Supplied)

The teen was on probation at the time of the attack for unrelated crimes. (Supplied)

9NEWS is forbidden from reporting the offender's name, where he lives or footage of the attack, because in the eyes of the law, he's still a child.

The opportunistic attack unfolded in front of horrified Boxing Day shoppers at Highpoint. Laying his boot into the side of a young, Senior Constable's face while he was defenceless; on his hands and knees arresting a shoplifter.

"Police certainly didn't consent to a non-custodial sentence," Mr Gatt said.

Arrested days after the incident, the offender was released on bail. Only to be found in possession of a mobile phone, breaching his bail.

After one month in custody, he was sentenced last Wednesday in the Children’s Court and given another chance, despite a history of home invasion and car theft.

State Attorney-General, Martin Pakula has defended the court's decision.

9NEWS is forbidden from reporting the offender's name. (9NEWS)

"In this case, the police prosecutors did not make a sentencing submission seeking a custodial sentence... That's a relevant factor."

"(Thanks to recent law changes) we're making it much more likely that young offenders will go into the adult system; that being the court system or the prison system."

Mr Gatt rebutted, "police officers shouldn't have to do the job of the courts for them."

The State Opposition was quick to point the finger in question time.

"Premier why is polling people about the future of ANZAC day more important than protecting our police?" Matthew Guy asked parliament.

To which, Mr Andrews replied, "in relation to offences against police and any mandatory minimums in relation to a custodial sentence, the laws passed by the previous government and supported by the then opposition did not cover minors."

Victoria Police is yet to clarify why its prosecutors didn't demand a custodial sentence.