Can perjury be filed if false averments are made without sworn affidavit

My husband has filed an appeal under section 29 pwadv act in sessions court against interim order of maintenance granted under section 23 pwadv act. He has made many false averments in his appeal. He has not given in an affidavit in support of these averments. He has submitted an affidavit along with his appeal which merely says that it is first appeal against this order. Can I still file perjury? My lawyer said perjury application can be filed only if false statements are sworn on affidavit. Please guide. Thanks