There have been chaotic scenes outside Novak Djokovic's lawyers' office in Melbourne, hours after a Federal Circuit Court judge ordered the Serbian tennis star be freed from Immigration detention.

Fans became rowdy as a black car emerged from the Rialto Towers car park, with one man jumping on the vehicle.

ABC reporter Tom Maddocks said police used pepper spray to control the crowds. Victoria Police could not confirm if any arrests had been made.

It was not clear if Djokovic was in the car.

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Immigration Minister Alex Hawke is considering whether to overturn the court decision allowing Djokovic to stay in Australia, a spokesman for the minister said in a statement.

"Following today's Federal Circuit and Family Court determination on a procedural ground, it remains within Immigration Minister Hawke's discretion to consider cancelling Mr Djokovic's visa under his personal power of cancellation within section 133C(3) of the Migration Act," the spokesperson said. 

Djokovic is seeking to be cleared to defend his Australian Open title. The tournament starts next Monday.

Victoria Police have been contacted for comment.

Djokovic was detained at Melbourne airport last week by Australian Border Force officers after he flew in from Dubai on a late-night flight.

Tennis Australia and the Victorian government had granted him an exemption from being vaccinated against COVID-19 before competing at the Open, on the grounds that he had recently had coronavirus.

In its submission to the court, the federal government argued Djokovic should not be exempt from vaccination requirements for international travellers

However, in his ruling, Judge Kelly noted the government had conceded Border Force's decision to interview Djokovic late at night and subsequently cancel his visa was unreasonable in the circumstances.