Kirsty McGukin was charged with theft and assault after the incident at the Woolworths supermarket in Erindale around 5.45pm on Sunday.

An off-duty police officer assisted staff in the supermarket following a suspected shoplifting incident.

A subsequent search of McGukin's bag revealed suspected stolen property from the store.

An ACT Policing spokeswoman said McGukin bit the employee on the calf while she was being apprehended.

McGukin was later taken to the ACT Watch House and charged with theft and assault occasioning actual bodily harm.

Magistrate Peter Morrison said ACT authorities faced significant difficulties in dealing with individuals who threatened the safety of others.

"Nobody wants to own them, [to] own the problem," Mr Morrison said.

McGukin was not in court for the hearing but a defence lawyer representing her said his client was vulnerable.

The lawyer said McGukin's mental state would continue to deteriorate if she did not receive adequate care.

On Saturday McGukin appeared in the ACT Magistrates Court in relation to a separate incident. Magistrate Bernadette Boss conducted a bail hearing in a loading garage due to safety concerns.

Despite receiving bail, McGukin was not released after she wrote ''F--- you'' on an undertaking to abide by bail conditions instead of signing her name.

When corrections officers sought to escort her into court on Saturday, McGukin refused to leave the van and became violent.

Dr Boss conducted the hearing outside the van after telling the court she did not have the authority to send McGukin to jail without speaking to her. McGukin levelled a string of obscenities during the hearing while refusing to sign her name on three separate bail undertakings.

Dr Boss instructed corrections officers to negotiate with McGukin to sign the bail papers guaranteeing her release or to take her to the Alexander Maconochie Centre.

Bailed was opposed on Monday and McGukin was required to undergo a mental health assessment.