The static route has to be via a gateway that is on a locally connected subnet.
For example, if I have IP 192.168.0.2/24 assigned to eth0, my routing table will have:
192.168.0.2/24 dev eth0 proto static scope link
I'm free to add a local route to a device outside 192.168.0.2/24 though: 192.168.10.1 dev eth0 proto static scope link
This just indicates that I should be able to resolve the MAC address associated with 192.168.10.1 through an ARP query,
same as other devices on my subnet.