Defender Lescott hasn't played for England since March while Richards won the last of his 13 caps in February 2012.
"I think we have a lot of games during the year so all the players will play," said Pellegrini.
He added: "Roy Hodgson must know who are the best England players to play in the national squad. Here at City they must show in games they play that they have the capacity to play in the national squad. It depends on both of them."
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