The Arsenal midfielder has been suffering from a cold this week and manager Roy Hodgson could opt for a central midfield of Frank Lampard and Steven Gerrard as his side bids to consolidate their lead at the top of Group H ahead of the final qualifier against Poland next Tuesday.
Hodgson was coy on his first XI at Thursday's press conference, but all 23 players trained on Thursday, so Leighton Baines should win his 20th cap at left-back in place of the injured Ashley Cole, while Phil Jagielka and Gary Cahill continue their partnership at centre-half.
Danny Welbeck, Wayne Rooney and Daniel Sturridge could all start, with Welbeck operating on the left and James Milner likely to come in on the right, although Andros Townsend will hope to make his debut from the bench.
Montenegro will be forced to name a weakened side with captain Mirko Vucinic, centre-back Marko Basa and midfielder Miodrag Pekovic all ruled out through injury.
Defender Miodrag Dzudovic is also doubtful for the visitors, who earned a 1-1 draw in the reverse fixture in March, but Manchester City forward Stevan Jovetic is available to play up front despite recent fitness concerns because of a lack of playing time with his club.
Victory against Montenegro followed by a win over Poland on Tuesday would guarantee England's place at the 2014 World Cup in Brazil.