Veteran full-back Neville, who has won 85 England caps, has endured an injury-plagued two years and is not expected to start United's Champions League final against Barcelona on Wednesday.
If Neville is picked by Capello he will equal Kenny Sansom's record for a full-back of 86 caps.
Capello has also recalled Tottenham striker Jermain Defoe, who missed the first three England games of 2009 through injury.
Manchester City winger Shaun Wright-Phillips, who was thought to require knee surgery, proved his fitness for Manchester City on Sunday and is also named in the squad.
But Wright-Phillips' City team-mate Nedum Onuoha, who had been tipped for a place in the squad, has missed out.
Full England squad:
Scott Carson (West Bromwich Albion), Robert Green (West Ham United), Paul Robinson (Blackburn Rovers)
Wayne Bridge (Manchester City), Ashley Cole (Chelsea), Rio Ferdinand (Manchester United), Glen Johnson (Portsmouth), Joleon Lescott (Everton), Gary Neville (Manchester United), John Terry (Chelsea), Matthew Upson (West Ham United)
Gareth Barry (Aston Villa), David Beckham (AC Milan loan from LA Galaxy), Michael Carrick (Manchester United), Steven Gerrard (Liverpool), Frank Lampard (Chelsea), Theo Walcott (Arsenal), Shaun Wright-Phillips (Manchester City), Ashley Young (Aston Villa)
Carlton Cole (West Ham United), Peter Crouch (Portsmouth), Jermain Defoe (Tottenham Hotspur), Emile Heskey (Aston Villa), Wayne Rooney (Manchester United)
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