Budanov was sentenced to 10 years in prison for killing 18-year-old Elza Kungayeva in Chechnya in 2000. An Ulyanovsk region court last month ordered his early release in a controversial decision that sparked protests in Chechnya.
He was to be released Friday, but Stanislav Markelov, a lawyer for Kungayeva's family, filed a complaint over the ruling, Interfax said.
Budanov has always maintained he believed Kungayeva was a rebel sniper and strangled her in a fit of rage during an interrogation. He has become a rallying figure for Russian nationalists.
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