Hong Kong activist Joshua Wong was released on bail Tuesday pending appeal against a jail term over pro-democracy protests.

Wong was jailed for three months last week, the second time he has received a prison sentence for his involvement in the Umbrella Movement.

Campaigners fear political debate in the semi-autonomous Chinese city is being shut down with a series of court cases against activists involved in the mass 2014 protests.

Wong, 21, who became the face of the rallies, was jailed on Wednesday last week on a contempt charge for obstructing clearance of a major protest encampment, to which he had pleaded guilty.

He was released on bail as a judge acknowledged he had grounds to appeal the sentence.

Wong is already on bail pending appeal against a six-month sentence for another protest-related offence.

Court of Appeal judge Andrew Cheung said Tuesday the original three-month term had "not given any, or any sufficient consideration" to Wong's age at the time of the offence, when he was a teenager.

Fellow activist Raphael Wong, who was jailed for four months and 15 days over the same incident, was denied bail as the judge ruled there were no grounds for appeal on the existing legal points.

"Facing uncertainty seems to be what has become normal under authoritarian government suppression," a tired-looking Wong told reporters outside the court as he emerged Tuesday night.

He described himself as "lucky" compared with Raphael Wong who is still in custody.

Dozens of protesters gathered outside court before the hearing Tuesday chanting "Political persecution! Abusing the courts! Civil disobedience! No fear!"

The Umbrella Movement was an unprecedented rebuke to Beijing as tens of thousands of protesters brought some of the city's busiest streets to a standstill.

They demanded fully free leadership elections to replace a system under which Hong Kong's chief executive is selected by a pro-Beijing committee.

The rallies failed to win concessions and since then leading activists have been charged over their involvement.

Beijing has been further incensed by some activists calling for independence for Hong Kong since the Umbrella Movement failed to win reform.

Wong's party Demosisto wants only self-determination.

Hong Kong has been governed under a "one country, two systems" deal since 1997, when Britain handed the territory back to China.

This allows citizens rights unseen on the mainland, including freedom of speech, a partially directly-elected legislature and an independent judiciary, but there are concerns those liberties are being eroded.

Wong was jailed for six months in August on unlawful assembly charges for involvement in the storming of a fenced-off government forecourt known as Civic Square in September 2014, which sparked the wider Umbrella Movement rallies.

He served over two months behind bars before being granted bail pending an appeal.

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