The UN court on January 31 sentenced Strugar to eight years in jail for the shelling of Dubrovnik, southern Croatia, in December 1991.
On Friday, the Appeals Chamber approved a request for provisional release which defence counsel submitted on December 12.
Attorneys Goran Rodic and Vladimir Petrovic said the condition for Strugar's release was a Montenegrin government guarantee that all the standards conditions set by the Appeals Chamber in such situations would be respected.