Mr Burke was previously jailed for failing to comply with a court order that he stay away from the school in Multyfarnham in Co Westmeath, where he used to teach.
The High Court ordered his release from prison last month.
He had been in jail since 2 September for contempt of court.
However, the judge warned Mr Burke that he would be subject to a daily fine of €1,400 a day if he breached the order directing him to stay away from the school.