Graphic CCTV footage has been released, which shows a woman in custody being dragged by a group of officers from the garage of a Sydney police station.

The footage was shown during a hearing of the state's Law Enforcement Conduction Commission, which is investigating the actions of 10 police officers.

The incident occurred in the early hours of April 9, 2016.

The woman, who cannot be named, had been taken to the police station and was then charged with a number of minor offences.

The video footage shows one policeman holding onto the woman's restrained hands and pulling her across the floor, before another then picks up one of her feet.

Several officers watch on as she is pulled to a search room.

The Commission heard the woman was a "difficult" prisoner.

Police allege she lashed out and assaulted officers before she was moved to the search room.

The woman faced the charges in local court and they were dismissed in 2017.

Officers used 'excessive force'

Counsel Assisting the Commission, David Huen, is now recommending that action be taken against some of the officers.

He recommended that one of the officers should be found to have used "excessive force whilst engaging in an inappropriate method of moving" the woman.

"Officer One engaged in serious misconduct which could result in either serious disciplinary action," Mr Huen said.

"Or referral to the Director of Public Prosecutions for advice with respect to a possible prosecution."

Mr Huen also said the officer gave untrue evidence to the local court.

He told the Commission two of the officers should be found to have committed serious misconduct, while four officers' conduct amounts to unsatisfactory performance over their statements to the local court.

Mr Huen recommended that there be no adverse findings against three of the officers.

Lawyers for the police officers have made written submissions to the Commission and a decision will be handed down at a later date.