A 15-year-old girl has received a police caution after an altercation with a 50-year-old woman on a V/Line train.
Police reported the incident occurred after a train departed Drouin station at 4.30pm last Monday.
They said the woman made a comment towards a group of teenagers before becoming agitated when they started filming her.
It is alleged the woman was struck in the head as she attempted to get the phone.
Police said the females exchanged punches and hair was pulled before passengers separated the pair.
The woman suffered a minor laceration on the top of her head.
Police arrested and cautioned a 15-year-old from Drouin.